Late Fees and Insiders

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Question:

Overdrafts may be one issue, but what about a late fee waiver on a loan for bank director - would this be a violation of Reg. O?

Answer:

Depends on why you waived the late fee and if you can prove that you always waive the fee in similar circumstances for all customers. If you cannot, then it is preferential treatment and could also possibly create fair lending concerns as with any other waiver of fees that are associated with making or servicing a loan.