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In Response To:
Thread Starter: Dan Persfull
Title: Re: Can we charge a returned item fee on this loan?

So even though it isn't a change in terms per Reg Z, we should be okay if we treat it like one and ensure proper notification before adding the fee?

Not IMO. If you didn't contract for the fee up front then you can't unilaterally add additional charges after confirmation. Especially if you're dealing with closed-end credit.

You need to be talking to the bank's attorney.