Our customers are able to make a mortgage payment online from a deposit account at another financial institution. The website discloses that payments received prior to 3 pm Central will be posted the date of entry (unless a weekend or holiday, then payment will post the next business day). Payments received between 3 pm and 12 am Central will be applied to the account the next business day. It also explains that late fees may be assessed depending on when the payment is received and provides alternatives for making the payment before 5 pm to avoid late fees.

Are we required to effective date the payments received after the cut-off (between 3 pm and 12 am) to the current business day? Or are we ok since we specify the requirements in writing for payments made in this manner?

We are struggling with the "prompt payment" requirement as well. Cut-off for our business day, which is prominently posted, is 3:00 pm. We have a process to capture those transactions that occur between our cut-off time and when our bank closes each day, but are unsure of how to treat a payment received on a Saturday.

On Saturday's we are processing all transactions on Monday's business day (our 3:00 cut-off is disclosed to customers). Do we have to back-date all payments received on a Saturday to that actual date or can we let the payment process on Monday's business?

We are back dating ours. More work for our operations people, but that is what they decided.