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Are we required to back-date payments made on consumer open-end lines of credit products (HELOCs and overdraft protection lines) to the prior business day if they are made in our lobby on Saturdays or in our night drop box on the weekend? – IBA Compliance Connection

IBA Compliance Connection

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Are we required to back-date payments made on consumer open-end lines of credit products (HELOCs and overdraft protection lines) to the prior business day if they are made in our lobby on Saturdays or in our night drop box on the weekend?

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No, Regulation Z does not require you to backdate payments received on a non-business day, but you must either credit payments on the “date of receipt” — meaning the date on which the payment reaches your institution — or ensure that any delays in crediting payments do not result in a late charge or a negative report to a consumer reporting agency (CRA). For example, if you receive payments over the weekend and credit them on the next business day, such as a Monday, you do not need to backdate those payments to Friday, but you must not charge late fees or submit negative reports to a CRA as a result.

For citations related to our guidance, please see below:

  • Official Interpretations, 12 CFR 1026, Paragraph 10(a), Comment 2 (definition of “date of receipt”)
  • Official Interpretations, 12 CFR 1026, Paragraph 36(c)(1)(i), Comment 3 (definition of “date of receipt”)