Per mobile RDC agreement - funds are available in 2-3 days. Customer pays a fee for the mobile RDC - 1% of deposit.

However, if the customer wants funds available immediately from the rdc deposit they pay 3%.

Are we venturing into credit territory with this premium fee for immediate funds?

Any thoughts are appreciated.

It would currently be a State law issue.

Interesting though - haven't seen anything of this sort in this area.

Most likely it is going to bring down the wrath of the legislatures - most likely at the Federal level if this practice becomes widespread.

The question is why? Does a fee this large actually have any relationship to loses suffered?? I would find that hard to believe if you are underwriting RDC like you should.

IMHO - You are just sticking a another bullet in the guns of the regulators by charging fees that have no relationship with risks presented.

Hopefully the fee amounts you list are hypothetical amounts as opposed to the actual fees you charge for the listed services. Discussing specific fees one charges and then asking others located at other institutions to give opinions on the appropriateness of those fees raises anti-trust issues.

Yes - hypthetical.

In addition, I wasn't asking about specific fees amounts - I was wondering if this concept would create a credit feature.

If you are venturing into credit and allowable interest charges, it would be determined by State law.

You are not deferring payment, so it would not be credit under Reg. B or Z.