Consumer Bill Pay — impact tolerance ≤ 1 business day — ITOL

Impact tolerance: ≤ 1 business day — any scheduled-payment date; late fees or missed due dates constitute breach (illustrative default — trace the derivation, then replace with your own harm analysis)

Definition: Scheduled and one-time bill payments initiated from online/mobile banking, delivered via ACH or check.

Why it is designated: Missed bill-pay dates cause customer late fees, credit-score damage, and utility shutoffs — direct financial harm to consumers. FTC/CFPB scrutiny of bill-pay reliability is elevated.