Is a TILA disclosure required for student accounts receivable that are charged interest/finance charges if the account is not paid in full? My institution is transitioning away from charging interest on 4-month deferred payment plans, but will instead charge interest on balances due exceeding a specified threshold at month-end, without regard to whether the student has enrolled in a payment plan.
Since the interest will no longer be specific to deferred payment plans meeting the definition of a loan, do we require a TILA disclosure? If so, do any other institutions that charge interest on balances due have a sample TILA disclosure they would like to share with us?