Q. Regulation Z states that banks can establish a reasonable cutoff time for payment of closed-end loans if the bank sends a conforming payment notice. However, our federal regulator says that the 3:00 p.m. cutoff time we set for closed-end loans is unreasonable. They claim that Federal Reserve guidance states that anything before 4:00 p.m. would be unreasonable. What has ABA heard to be considered a reasonable cut-off time on closed-end credit?
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