How do you count grace period days? For example, if a loan payment is due on the 1st of the month, and the grace period is 10 days, do you agree that if the payment is not made, a late fee would be charged at the end of the day (during update) on the 11th--which would appear on the loan on the system on the morning of the 12th?

IN law allows the borrower to pay within 10 calendar days before a late charge can be assessed. Due to the absence of the word "business", our then cutoff time and discussions with the DFI our late fees are not assessed until the 11th calendar day after the payment is due.

We have since changed to an end of day processing which is 5:00PM (closing). We chose not to adjust the timing of the late charge assessment.

Thank you, Dan!