Monthly Regulatory Compliance Change Management Summary
As part of our ongoing effort to keep you informed, each month we send to you a summary of the work we’re doing to ensure compliance with the ever-changing regulatory landscape.
All items in May are in compliance with our regulatory change management program.
To provide you more information, we also host a monthly conference call. The next call will take place on Thursday, June 27, 2024 at 3 p.m. EDT. To register or send a question to be addressed on the call, please reach out to compliancechgmngt@cenlar.com. If you have registered for a previous call, you do not need to request registration again. This call will be recorded and posted to CenAccess, so that you may listen at your convenience.
Please note, all questions to be addressed on the call are required to be provided least 24 hours in advance. Any questions received after 3 p.m. EDT on the day before the call will not be answered during the call. You may also submit questions related to the regulatory compliance change management program at any time to compliancechgmngt@cenlar.com. Our compliance department will respond within two business days of receipt (excluding weekends and holidays).
Noteworthy Items:
- Q13154 – South Carolina REG: 2024 Adjustment of Dollar Amounts (Effective 7/1/2024):
This client notification pertains to updates to the late fee regulations within the state of South Carolina.
The South Carolina Department of Consumer Affairs has adjusted the dollar amounts in the Consumer Protection Code based on the Consumer Price Index for Urban Wage Earners and Clerical Workers. The updated dollar amounts are effective from July 1, 2024 to June 30, 2026.
Delinquency charges
(1) With respect to a consumer loan including an open end consumer loan pursuant to a lender credit card or similar arrangement, and any refinancings or consolidations of all such consumer loans, the parties may contract for a delinquency charge on any installment not paid in full within ten days after its due date, as originally scheduled or as deferred, in an amount, not exceeding $25.50 (updated for 2024) which is not more than five percent of the unpaid amount of the installment.
(2) Notwithstanding subsection (1) the lender may contract for and receive a minimum delinquency charge not to exceed forty percent of $10.20 (updated for 2024) as adjusted pursuant to § 37 1 109. The lender may contract for such a minimum charge even though the charge exceeds five percent of the unpaid amount of the installment.
- Q13422 Oklahoma REG: Title 160, Ch. 20, Appendix I: Changes in Dollar Amounts – July 1, 2024 (Effective 7/1/2024):
This client notification concerns updates to delinquency charges for Oklahoma Uniform Consumer Credit Code loans.
The Oklahoma Department of Consumer Credit has adjusted the dollar amounts set forth in the Uniform Consumer Credit Code based on the Consumer Price Index for Urban Wage Earners and Clerical Workers. The following changes are effective July 1, 2024.
Delinquency Charges
With respect to a consumer credit sale, refinancing, or consolidation, the parties may contract for a delinquency charge on any installment not paid in full within 10 days after its scheduled due date for an amount not exceeding the greater of 5% of the unpaid portion of the scheduled installment or $32.00 (updated for 2024).
With respect to a consumer loan, refinancing or consolidation, which is not precomputed, the parties may contract for a delinquency charge on any installment not paid in full within 10 days after its scheduled due date in an amount not less than $32.00 (updated for 2024) nor more than the greater of 5% of the unpaid amount of the payment.