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by Randy Carey: You can charge a customer for anything you want to as long as the charges are allowed under State law and you assess whether or not such a charge will not be deemed a UDAAP by the regulators. However, any charge that is assessed for days on which the customer cannot cure the situation is a dangerous plank to wander out on.
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by Ken Golliher: The law does not take care to prohibit every action that is unfair or predatory. Involve the younger, less experienced members of your staff in evaluating things like this. They have yet to drink the Kool-Aid and cannot yet rationalize that the bank can do anything it wants just because it's the bank.
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