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In Response To:
Thread Starter: Inspector
Title: Re: Charging a late fee on cc

What you are describing is why I noted that it is important that the agreement be clear about this type of situation. Is the annual fee advanced? How is the late fee assessment described? How is the minimum payment due described? etc.

There isn't a clear cut prohibition in Reg Z but a lender could very easily place a restriction on itself by the way the contract is worded.