It seems to me that this answer is an obvious no, but I'm just looking for some advice.

We are a federally chartered bank with an indirect lending program containing dealers all over the country. In order to simplify things, we would like to adopt a universal late charge policy to apply to all these loans.

I do realize each state has its own law regarding late charges, but does anyone have any advice regarding a universal late charge, or are we just going to have to bite the bullet and do a state by state analysis?

In addition, I am under the impression that the state where the customer is making the purchase is the applicable law, and not where they have residence. Is this correct?

Thanks

You could create a universal late charge as long as it doesn't violate any state laws. That being said, you may need to bite the bullet and understand each states requirements.

Talk to your attorney regarding your Federal preemption powers if you are going to be the original creditor. If you are just buying the paper from the dealers, you are going to be stuck with State laws.