Improperly Coded the Accrual Basis-Reg Z?

Answered by:

Question:

We had a system glitch that improperly coded the accrual basis. It should have been coded as 365/actual but was instead coded as 360. These are consumer customers. Of course we are going to correct the accrual basis and credit the account for the overcharged amount. Do we need to do anything else re contacting the consumers? Is this found in Z anywhere?

Answer:

Apparently this question relates to some type of consumer credit and Regulation Z. There is too little information to get a clear understanding of what was contracted and disclosed. If there were disclosures and they accurately reflected the contract, then an error in servicing would be a breach of contract, not a disclosure error. Take whatever actions necessary to make the customer whole and provide an explanation.