OK. I've researched TILA, Reg AA, Oklahoma lending, etc... I've even searched previous posts concerning late fees, disclosures required, ad infinitum. I need some help on this: Our upgraded software now allows us the option of capitalizing late fees on HELOC's. Nowhere have I been able to find a resource that tells me I can't.
The system allows for the late fee to appear in the loan accrual balance, the customer's periodic statement also shows it, BUT the regular payment does not reflect the additional charge. IS THIS OK???

That sounds like pyramiding to me - but it's late, and my brain is mush so I can't find the cite. Can anyone help us out?

I think that this is pretty typical on open-end credit plans.

The late fee is added to the principal balance. There is no additional penalty assessed on the original late fee. Therefore, I don't see it as pyramiding... What I'm afraid of assuming, though, is that our software allows us to set up the HELOC this way, sooooooo it should be OK? Right?