As to Reg. D, look at 204.2(C)(1) and footnote 1. Imposing a penalty in the first 6 days has only a few exceptions. After that you may opt to waive it for many reasons.
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AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell