Regulation D sets a minimum withdrawal penalty for accounts that can be considered “time deposits” for reserve requirement purposes: “A time deposit from which partial early withdrawals are permitted must impose additional early withdrawal penalties of at least seven days’ simple interest on amounts withdrawn within six days after each partial withdrawal.” 12 CFR 204.2(c)(1)(i).

 However, the regulations do not set a maximum withdrawal penalty, and neither does Illinois law. In our view, the general rule in the Illinois Banking Act, which states that banks may charge any interest or fees “subject only to the provisions of [Subsection 4(1)] of the Interest Act,” provided they are based on a bank’s “prudent business judgment and safe and sound operating standards,” would apply. 205 ILCS 5/5e. Moreover, Subsection 4(1) of the Interest Act states that a bank is authorized “to receive or contract to receive and collect interest and charges at any rate or rates agreed upon by the bank or branch and the borrower.” 815 ILCS 205/4(1).