I know that one of the things that will be required to be on each coupon if we choose to provide coupon books after 1/10/14 is the amount of any late payment fee. Our current coupon books show the amount due, the due date, and the amount due if paid after the last day of the courtesy period. The fee is included in the second payment due amount. Does that meet the new requirement to disclose the amount of late payment fee or must the fee itself be separated from the payment due amount?

I think it is pretty clear that the actual fee has to be stated unfortunately:

The description of any late fee charges includes the date of the late fee, the amount of the late fee, and the fact that a late fee was imposed.

Thanks, Randy - I thought so, too, but I figured I'd at least ask. So, that means we'll need to send our existing coupon book customers new books, correct?