Consumer Loan Payment Processing — impact tolerance ≤ 2 business days — ITOL
Impact tolerance: ≤ 2 business days — if delayed posting causes late-fee assessment or credit-bureau derogatory reporting (illustrative default — trace the derivation, then replace with your own harm analysis)
Definition: Accept and post consumer loan payments (auto, personal, HELOC) via ACH, check, card, and online channels.
Why it is designated: A missed posting causes wrongful late fees, credit-bureau errors, and CFPB complaint exposure under Reg Z and the FCRA (Fair Credit Reporting Act). The binding constraint is the bank's ability to process payments at the grace-period boundary.