Truth in Lending: 9.10.8 Pyramiding of Late Fees
Effective January 10, 2014, the CFPB adopted a rule similar to the prior FRB rule (discussed in companion materials), but removed any reference to a “full” payment and instead applied the requirement only to “a periodic payment.”1390 The distinction between the meanings for “full” payment and “periodic” payment intended by this change in the regulations is unclear.