A commercial loan bill looks like one number, but it is built from many small ones: the balance on each day, the rate for each day, how many days the contract says to count, and the fees on the money the borrower has not drawn. The loan agreement sets every one of those rules, and each deal sets them a little differently. When the bank's loan system is set up one way and the signed agreement says another, the bill is wrong every quarter until someone recalculates it.
This guide is for anyone who bills, checks, disputes or pays commercial loan interest: billing analysts, loan servicing officers, agency and participation staff, loan operations and accounting managers, borrowers' controllers, auditors, and the leaders deciding whether to automate the check. No background needed.
Imagine you are a loan servicing officer at a regional bank in Ohio. It is Thursday, October 1, 2026, at 9:12 a.m. The third-quarter billing run has printed 412 bills, and they go out at 4:00 p.m. One of them is for Kestrel Ridge Foods, a food manufacturer with a $7.8 million term loan and a $15 million revolving line. The bill says $186,904.10.
The loan was moved onto the bank's loan system on April 3, the day the credit agreement was amended and restated. On page 32, section 2.4(c) says the term loan's interest is counted on twelve 30-day months. July and August have 31 days each. The system was set up with the bank's default, which counts actual days.
Credit agreement · §2.4(c), p. 32
Day count
30/360, twelve 30-day months
Jul 1 – Aug 31
60 days
Interest
$80,746.50
Arithmetic
$7,814,177.42 × 6.20% × 60 ÷ 360
Loan system set-up · since Apr 3
Day count
Actual/360, called 365/360
Jul 1 – Aug 31
62 days
Interest
$83,438.05
Arithmetic
$7,814,177.42 × 6.20% × 62 ÷ 360
$186,904.10 billed$184,212.55 recalculated$2,691.55 too much, all on one line.
Everything else on the bill is right: the three Term SOFR rate resets, the $1,250,000 draw on August 14, the $600,000 repayment on September 18, the fee on the unused part of the line. The same set-up added $1,378.07 to the second-quarter bill, which the borrower's controller paid on July 1. Her own spreadsheet would have found it sooner or later.
Recalculating each bill from the signed agreement, before it is sent, catches the two extra days, and proves that they are the only thing wrong.
How a commercial loan bill is built: days, rates, floors, fees, default interest and the contract behind each
The arithmetic, the conventions, the court decisions, the errors and the rules, explained without selling anything. If you have never checked a loan bill by hand, start here.
01 · In plain words
Why two business loans at the same bank and the same rate can owe different interest for the same quarter
When a business borrows from a bank, it pays interest for every day it has the money. The bank works out the interest for a period, usually a month or a quarter, and sends a bill. For a mortgage or a car loan the bill is predictable, the same payment every month. For a business loan it rarely is.
The balance moves when the business draws on its line of credit or pays some back. The rate moves, because most business loans float over a published benchmark rate that is reset every month or every quarter. And the business also pays fees: a small charge on the part of its credit line it has not used, a charge for each letter of credit the bank has issued on its behalf, and sometimes extra interest when it has broken a promise in the agreement.
Every one of those pieces is set by the loan agreement, the long contract both sides signed. The agreement says which benchmark rate applies and on which day it is read, and what margin is added on top. It says whether there is a minimum rate (a floor), how many days a month counts as, whether the year has 360 or 365 days, what the unused fee is charged on, and when the higher default rate starts and stops. Two loans at the same bank can answer each of those questions differently, and often do.
The bank's loan system does the arithmetic. It does exactly what it was set up to do when the loan was entered, or "boarded", and it repeats that set-up on every bill until someone changes it. If a person keyed one term differently from the agreement, or the system applied the bank's default where the agreement said something else, every bill carries the same mistake. Borrowers with a careful controller find some of them. Mistakes that favor the borrower are rarely reported at all.
Checking a bill means rebuilding it from the agreement: the terms from the signed documents and their amendments, the published rates for each reset, the draws and repayments from the loan's history, then the days, the balance and the rate for every slice of the period. When the rebuilt bill and the system's bill differ, the difference points to the term the system has wrong. When a borrower or a bank that bought a share of the loan disputes a bill, the same rebuild is the answer.
From signed agreement to paid bill: where the interest check sits
The agreement is signed and the loan is boardedKestrel Ridge's amended agreement is signed on April 3, 2026 and entered in the loan system the same day, with twelve pricing and fee terms.
Rates reset and money movesTerm SOFR is read on June 29, July 30 and August 28 in the example; $1,250,000 is drawn on August 14 and $600,000 repaid on September 18.
Interest and fees build up every dayEach day's balance, rate and day count add a little; the quarter ends on September 30.
The bill is calculated and checkedTen slices of the quarter, each with its own days, balance and rate. This is where the two extra days on the term loan are caught, or sent.
The bill is paid, disputed or shared outThe borrower pays or questions it; banks that bought shares of a loan receive theirs and check them too.
Step 4 is the subject of this guide. The bank, borrowers, people and figures in this example are fictional.
Four facts about loan interest that catch newcomers out
A 360-day year raises the rate
Most commercial loans divide the yearly rate by 360 and charge it for every actual day. Over a normal year the borrower pays 365/360 of the stated rate, about 1.39% more interest; a federal appeals court put the increase at 0.01389 times the rate.1
The contract wins over the system
Courts have upheld the 360-day method where the note spells it out.1,2 The same logic cuts the other way: a system billing a method the note never states has nothing to stand on.
Underbills get no complaints
A borrower who is billed too little does not call. A bank that only investigates disputes finds its overbills and never its underbills, and the participants who bought shares of those loans are short too.
Most of the market's rules are voluntary
The conventions for SOFR loans come from the Alternative Reference Rates Committee, and each one says parties may choose otherwise.3,4 No federal rule sets how a business loan's interest is counted; consumer billing rules exempt business credit.5
Day count, accrual period, fixing, unused line fee: the four terms every loan bill uses
Day count
The rule for counting a period's days and a year's length: Actual/360, Actual/365 or 30/360, among others.
Accrual period
A slice of the billing period in which the balance and the rate stay the same. A new one starts at every draw, repayment or rate change.
Fixing
The published value of a benchmark rate, such as one-month Term SOFR, on the day the agreement says to read it.
Unused line fee
A yearly percentage charged on the part of a credit line the borrower has not drawn. Also called a commitment fee.
Balance × rate × days ÷ year: the formula behind every line of a commercial loan bill
In shortEvery interest and fee line is the same four-part calculation. The hard part is choosing each input: which balance, which rate, which days, which year. A quarter with draws, repayments and resets becomes many short calculations, one for each slice in which nothing changes, added up at the end.
A federal appeals court summed up the arithmetic in one line: "interest = principal x rate x time".1 Time is the fraction of a year the money was out, and that fraction is where the conventions come in. Lenders have long used three ways to set it, which the same court listed as "the 365/365 method (exact day interest), the 360/360 method (ordinary interest) and the 365/360 method (bank interest)".1
Input 1
The balance
What was outstanding on each day: the loan, or for a fee, the unused commitment or the letters of credit. It changes on the day money moves, and the agreement says whether that day counts at the old balance or the new.
Input 2
The rate
A fixed rate, or a benchmark fixing plus a margin, tested against any floor. For Kestrel Ridge's line: Term SOFR of 3.86192% plus a 2.35% margin is 6.21192% for September, using the sample's own fixings.
Inputs 3 and 4
The days and the year
Actual days or 30-day months, over a 360- or 365-day year, as the day-count clause says. Kestrel's agreement uses 30/360 for the term loan and Actual/360 for everything else.
What one quarterly bill is made of
Two-thirds of Kestrel Ridge's quarterly bill is term loan interest
The $184,212.55 recalculated for July 1 to September 30, 2026, by part
10accrual periods
Term loan interest, 2 periods$120.2K
Revolving loan interest, 5 periods$55.8K
Unused line fee, 3 periods$8,282
Fictional example from this guide
Show the numbers
Part
Value
Term loan interest, 2 periods
$120.2K
Revolving loan interest, 5 periods
$55.8K
Unused line fee, 3 periods
$8,282
Ten accrual periods make the bill: two for the term loan, split at the September 1 principal payment; five for the revolving loans, split at the two rate resets, the August 14 draw and the September 18 repayment; three for the unused fee, split where the drawn amount moved. Each period is rounded to the cent and the ten are added. The difference in the example sits in one of the ten: the July–August term loan line.
Line
Days
Balance
Rate
Basis
Interest
Term loan, Jul 1 – Aug 31
60
$7,814,177.42
6.20%
30/360
$80,746.50
Term loan, Sep 1 – Sep 30
30
$7,626,677.42
6.20%
30/360
$39,404.50
Revolver, Jul 1 – Aug 2
33
$2,880,000.00
6.47062%
Actual/360
$17,082.44
Revolver, Aug 14 – Aug 31
18
$4,130,000.00
6.33741%
Actual/360
$13,086.75
Unused fee, Jul 1 – Aug 13
44
$11,370,000.00 unused
0.30%
Actual/360
$4,169.00
Five of the ten lines. The unused amount is the $15,000,000 line less $2,880,000 of loans and a $750,000 letter of credit. All figures are from the fictional example.
The July–August term loan line, worked one step at a time
Step
What you do
Result
1 · Balance
Take the term loan balance outstanding through the period
$7,814,177.42
2 · A year's interest
Multiply by the yearly rate: $7,814,177.42 × 6.20%
$484,479.00 a year
3 · One day's interest
Divide by the year the day count uses, 360 days
about $1,345.78 a day
4 · Count the days
Under 30/360, July and August are 30 days each
60 days
5 · The line
One day's interest × 60, rounded to the cent
$80,746.50
What the system did
Counted the actual days, 31 + 31 = 62: one day's interest × 62
$83,438.05, which is $2,691.55 (two days) too much
The daily figure is shown rounded; the calculation carries every decimal and rounds once, at the end of the line.
03 · The rules and their dates
Who sets the rules for a commercial loan bill, and what changed between 2020 and 2026
Status as of October 2026
In shortThe loan agreement is the rule. Federal consumer billing law exempts business credit, so the market's own conventions, state contract and usury law, and the court decisions on how to read a note fill the space. Since 2020 LIBOR has ended, SOFR conventions have been written, Congress has legislated a replacement for old contracts, and in April 2026 the model risk guidance changed.
From the first SOFR loan conventions to the 2026 model guidance, nine dates shape today's bills
Jul 22, 2020ARRC conventions for SOFR in arrears
Daily simple or compounded SOFR, a business-day lookback, Actual/360, floors tested daily.
Mar 5, 2021Spread adjustments fixed
The five-year median gaps between LIBOR and SOFR: 0.11448% for one month, 0.26161% for three.
Jul 2021ARRC conventions for Term SOFR
The rate read two bond-market business days before each period and held for it.
Mar 15, 2022LIBOR Act
Congress sets a replacement for contracts with no workable fallback.
Sep 29, 2022Honchariw decided
A California court holds 9.99% default interest on a $5.6 million loan's whole balance a penalty.
Feb 27, 2023Regulation ZZ in force
The Fed names the replacement: from July 3, 2023, CME Term SOFR plus a fixed adjustment in those contracts.
Sep 30, 2024LIBOR ends
The last synthetic US dollar settings are published for the final time.
Apr 17, 2026SR 26-2 replaces SR 11-7
New model risk guidance excludes spreadsheet arithmetic and leaves generative AI out of scope.
Sep 17, 2026Prime rate to 7.00%
Every prime-based bill for the third quarter splits on this date.
Index, fixing date, margin and pricing grid, floor, day count, fees and their base, default rate and its trigger, notices, rounding.
Governs; amendments in date order
ARRC conventions
Actual/360; Term SOFR read two U.S. Government Securities Business Days before the period; floors daily for SOFR in arrears; rates to five decimals, amounts to two.3,4
Voluntary recommendations, 2020 and 2021
LIBOR Act and Regulation ZZ
For contracts with no workable fallback: the matching tenor of CME Term SOFR plus 0.11448% (one-month LIBOR), 0.26161% (three-month), 0.42826% (six-month) or 0.71513% (twelve-month); overnight LIBOR became SOFR plus 0.00644%.6
Rule effective February 27, 2023; replacement from July 3, 2023, the first London banking day after June 30
Regulation Z, 12 CFR 1026.3(a)
Exempts "An extension of credit primarily for a business, commercial or agricultural purpose".5
Current
12 CFR 7.4001
For national banks, "interest" includes late fees, so they follow the bank's home-state rate rules.11
Current
State usury and penalty law
New York: no rate limit at $2.5 million and above; California: charges on the whole balance for a late payment can be penalties.12,13,8
Varies by the law the agreement chooses
SR 26-2 / OCC 2026-13 / FDIC FIL-15-2026
Model risk guidance; "simple arithmetic calculations" and "deterministic rule-based processes" are not models.9
April 17, 2026
A claim to correct. Some servicing pages still describe "LIBOR loans". The last US dollar LIBOR settings were published on September 30, 2024, which the UK regulator called "the end of LIBOR overall".7 A loan whose documents still name LIBOR is billed on whatever its fallback clause, or the LIBOR Act, put in its place, and that replacement rate is what a check has to use.
04 · Day counts
Actual/360, Actual/365 and 30/360: what each day count does to the same balance
In shortActual/360 charges for every calendar day but divides the yearly rate by 360, so a year costs 365/360 of the stated rate. Actual/365 charges exactly the stated rate. 30/360 treats every month as 30 days, so a year also costs exactly the stated rate, but a 31-day month costs the same as a 30-day one. Over a year two of the three agree; month by month all three differ.
Over a full year only Actual/360 charges more than the stated 6.20%
Interest above the stated 6.20% for one year on $10,000,000, by day count, in dollars to the nearest dollar
Actual/360, leap year (366 days)$630,333.33 for the year10,333
Actual/360, normal year (365 days)$628,611.11 for the year8,611
Actual/365$620,000.00, exactly 6.20%0
30/360$620,000.00, exactly 6.20%0
Illustrative · replace with your own numbers · Arithmetic: balance × rate × days ÷ year. 2028 is the next leap year.
Show the numbers
Item
Value
Actual/360, leap year (366 days)
10,333
Actual/360, normal year (365 days)
8,611
Actual/365
0
30/360
0
On $10 million at 6.20%, Actual/360 costs $8,611.11 a year more than Actual/365, and $10,333.33 more in a leap year. That is the "about 1.4%" that borrowers have sued over: 365 ÷ 360 is 1.01389. Banks call it ordinary practice, and it is: the ARRC recommends Actual/360 for SOFR loans because it "is the standard convention in US money markets", while noting that other day counts are possible and that sterling loans count 365 days.3,4
Month by month, the three methods split apart
A 31-day month costs one day more under Actual/360; February costs two days less
Kestrel Ridge's term loan balance of $7,814,177.42 at 6.20%, one month's interest
30/360Actual/360
31-day month (July, August)$40.4K$41.7K
30-day month (September)$40.4K$40.4K
28-day February$40.4K$37.7K
Fictional example from this guide
Show the numbers
30/360
Actual/360
31-day month (July, August)
$40.4K
$41.7K
30-day month (September)
$40.4K
$40.4K
28-day February
$40.4K
$37.7K
That is the Kestrel Ridge bill in miniature. The term loan's clause says "a 360-day year consisting of twelve 30-day months", so July and August count 30 days each. The system counted 31 and 31. The same mistake reached back into the second quarter:
Quarter
Days billed and allowed
Extra interest
Third: Jul 1 – Aug 31
62 billed, 60 allowed (30 + 30)
$7,814,177.42 × 6.20% × 2 ÷ 360 = $2,691.55
Second: Apr 3 – May 31
59 billed, 58 allowed (28 in April, 30 in May)
($7,814,177.42 + the $187,500.00 paid June 1) × 6.20% × 1 ÷ 360 = $1,378.07
The second-quarter day falls before the June 1 principal payment, so it is charged on the higher balance.
Read the definition
30/360 comes with several month-end rules
Market definitions of 30/360 differ on what to do when a period starts or ends on the 31st or on the last day of February. A loan agreement may define its own. The calculation has to follow the definition in the document, word for word, and a check should flag a 30/360 clause that is silent on month-ends.
One facility, two bases
Term loan and revolver can differ
Kestrel's agreement puts the amortizing term loan on 30/360, so each quarter's interest comes out even, and the revolver and fees on Actual/360, the money-market convention. A loan system set up with one basis per borrower, instead of one per facility, gets one of them wrong on every bill.
05 · The 365/360 cases
The 365/360 lawsuits: what Ohio, Illinois and the Eighth Circuit decided about "per annum"
In shortBetween 2011 and 2013, borrowers brought class actions arguing that a rate stated "per annum" means a 365-day year, so Actual/360 overcharged them. Appeals courts in Illinois, the Eighth Circuit and the Ohio Supreme Court read the notes as a whole and sided with the banks where the note stated the 365/360 method. The lesson for servicers runs both ways: the words in the note decide, and the system has to bill what the words say.
Four appellate rulings in two years upheld the 365/360 method where the note stated it
2011RBS Citizens v. RTG-Oak Lawn
Illinois Appellate Court: the note's language was not ambiguous and clearly disclosed the method.
2011Asset Exchange II v. First Choice Bank
Illinois Appellate Court: "per annum" was defined in the note as a 360-day year, so no conflict.
Oct 6, 2011Kreisler v. National City Bank
Eighth Circuit, Illinois law: a $48,407 note's 365/360 clause is clear and enforceable.
Nov 21, 2012JNT Properties v. KeyBank
Ohio Supreme Court reverses the court of appeals: "inartful" wording, but not ambiguous.
After 2012Ely Enterprises class
Ohio's Eighth District: after JNT, notes with similar language raise no common question for a class.
The Kreisler note read: "The annual interest rate for the Note is computed on a 365/360 basis; that is, by applying the ratio of the annual interest rate over a year of 360 days, multiplied by the outstanding principal balance, multiplied by the actual number of days the principal balance is outstanding."1 The JNT Properties note used nearly the same words.14
The borrower in Kreisler argued that "per annum" in the variable-rate clause meant twelve calendar months, so the bank had charged "101.389% of the agreed upon interest rate". The Eighth Circuit disagreed: "per annum" appeared only in the definition of the bank's prime rate, and the payment clause "clearly sets out the time factor and the method for calculating interest, which the Bank followed."1 The court added that the clause "may have been clearer had it stated that the 'annual interest,' rather than the 'interest rate,' is calculated on a 365/360 basis".1
In JNT Properties, the trial court had granted summary judgment to the bank, and the court of appeals reversed, finding the note ambiguous. The Ohio Supreme Court reinstated judgment for the bank: the "inartful use of the term 'annual interest rate'" did not make the clause ambiguous, because a reasonable reader would understand the note to define the method of computation.2 A later Ohio appeals decision applied JNT to undo a class certification: once similar notes are not ambiguous as a matter of law, there is no common question to try.14
What the cases mean for a bill
For the drafter
Say the method in words
The clauses that held up spelled out the arithmetic: the ratio over 360 days, times the balance, times the actual days. A bare "365/360" or a rate "per annum" with no time factor invites the argument.
For the servicer
The defense is the document
Every one of these banks won because it billed what its note said. A system that bills Actual/360 on a note that says 30/360, as in the Kestrel example, has the opposite problem: the borrower has the document on its side.
The decisions date from 2011 to 2013. Our searches found no later appellate ruling that changes them. The outcome in any case depends on the note's exact wording and the state's contract law.
06 · SOFR conventions
Term SOFR, daily simple SOFR and compounded SOFR in arrears: when the rate is known and how it builds up
In shortTerm SOFR is read before the period starts and held for the whole period, like LIBOR was. Daily simple and daily compounded SOFR are read every day during the period, so the rate for the period is known only at the end. A lookback shifts each day's reading a few business days earlier so the bill can be ready on time. Each choice changes the arithmetic a checker has to rebuild.
Term SOFR is the easiest to bill; compounded SOFR in arrears needs the most daily data
The three SOFR forms against five things a servicer has to handle
EasyCareHard
Rate known up frontDaily ratesMid-period prepaymentCompoundsFloorTerm SOFR, in advanceEasyEasyEasyEasyEasyDaily simple SOFR, in arrearsHardHardCareEasyCareDaily compounded SOFR, in arrearsHardHardHardHardHard
A forward-looking one-, three- or six-month rate published by CME, read once and held for the period
The rate "published two US Government Securities Business Days prior to the first day of the interest period and held for the entirety of the interest period"; Actual/360.4
Daily simple SOFR
Each day's overnight SOFR times the day's principal, added up
"SOFR is sourced daily and multiplied by the outstanding principal"; over weekends and holidays the preceding business day's rate applies, weighted by calendar days.3
Daily compounded SOFR
Overnight SOFR compounded daily on the balance, or on a rate index
Three methods: compound the balance, a cumulative compounded rate, a noncumulative compounded rate.3
Lookback, observation shift, payment delay
With SOFR in arrears, the last day's rate is published the morning after the period ends. To bill on time, agreements use a lookback: each day of the period takes the rate from a few business days earlier. The ARRC's own example is a five business day lookback, in which a loan starting June 1 takes the May 25 rate, and the bank knows every rate by June 23 for a period that ends June 30.3
The ARRC recommends a lookback "with no observation shift" for syndicated loans. An observation shift also moves the day weights to the earlier dates, and the ARRC found it "could result in a borrower paying too much or too little interest if the loan is prepaid in a period" when the two calendars have different numbers of days.3 Agreements can buy time in other ways too, such as a payment delay or a lockout that freezes the rate for the last few days. Whichever the agreement picks has to be rebuilt exactly.
Daily simple SOFR over a weekend, worked
Interest day
Rate applied
Days weighted
Interest on $5,000,000
Friday
SOFR from five business days earlier, 3.90%, plus a 2.25% margin = 6.15%
3 (Friday, Saturday, Sunday)
$5,000,000 × 6.15% × 3 ÷ 360 = $2,562.50
Monday
3.92% + 2.25% = 6.17%
1
$5,000,000 × 6.17% × 1 ÷ 360 = $856.94
Illustrative rates. Friday's rate covers Saturday and Sunday because SOFR is not published on weekends. A checker who weights Friday's rate for one day instead of three, or looks for a Saturday rate that does not exist, gets a different bill. The ARRC says simple and compounded interest usually differ by "a few basis points or less".3
07 · Fixing dates and calendars
Fixing dates, borrowing notices and the bond-market calendar behind every Term SOFR period
In shortA Term SOFR loan reads its rate two U.S. Government Securities Business Days before the period starts. That calendar belongs to the bond market, so it is close to the bank's own holiday calendar and different from it. Reading the rate on the wrong day gives a perfectly real rate for the wrong day, which is why fixing-date errors survive a casual review.
A September 1 period needs a notice by August 27 and the rate published August 28
The steps behind one Term SOFR interest period in the example
1Borrowing notice
Three bond-market business days before: Thursday, August 27.
BorrowerAug 27
2Rate fixed
One-month Term SOFR as published two business days before the period: Friday, August 28.
Benchmark administratorAug 28
3Period starts
Interest accrues at the fixing plus the margin.
Loan systemTue Sep 1
4Period ends
The last day counted; quarterly bills close on September 30.
Loan systemSep 30
5Bill sent
Quarterly in arrears: due October 1.
Loan servicingOct 1
Fictional example from this guide
Show the numbers
Step
What happens
Who
Time
Borrowing notice
Three bond-market business days before: Thursday, August 27.
Borrower
Aug 27
Rate fixed
One-month Term SOFR as published two business days before the period: Friday, August 28.
Benchmark administrator
Aug 28
Period starts
Interest accrues at the fixing plus the margin.
Loan system
Tue Sep 1
Period ends
The last day counted; quarterly bills close on September 30.
Loan system
Sep 30
Bill sent
Quarterly in arrears: due October 1.
Loan servicing
Oct 1
The ARRC recommends that the calendar in the agreement be "US Government Securities Business Days", any day except a weekend or a day on which the Securities Industry and Financial Markets Association recommends that its members' fixed income departments close for the whole day. SOFR, and so Term SOFR, is not published on a full-close day.4
The borrowing notice is three of those days before the period, "similar to the LIBOR convention today".4 If a rate is missing on the day, the ARRC's suggested fallback takes the rate from the first preceding business day, no more than three business days back.4
In the example's billing run, one loan's September period used the fixing published on September 1, the first day of the period, instead of August 28. The loan is a $23,842,000 term loan at Term SOFR plus a 2.10% margin, Actual/360, and September has 30 days:
Fixing used
Rate
Interest for September
Right: Aug 28, 3.86192%
3.86192% + 2.10% = 5.96192%
$23,842,000 × 5.96192% × 30 ÷ 360 = $118,453.41
Billed: Sep 1, 3.84115%
3.84115% + 2.10% = 5.94115%
$23,842,000 × 5.94115% × 30 ÷ 360 = $118,040.75
Underbilled
$412.66
No borrower complains about that. The banks that bought shares of the loan are short their part of it. Both fixings are the example's sample rates.
Where to look first. A quarter's interest that is off by a day or a fraction of a basis point usually traces to a calendar: a holiday on one calendar and not the other, a period end that rolled under the business-day rule, or a fixing read on the period's first day. The ARRC's business-day rule for payment dates is "Modified Following": the next business day, unless that falls in the next month, in which case the preceding one.4
08 · Floors and spread adjustments
Rate floors and spread adjustments after LIBOR, and why floors sit idle at 2026 rates
In shortA floor sets a minimum for the benchmark; a spread adjustment adds a fixed amount to SOFR to make up for its being lower than LIBOR was. For new loans the ARRC says the floor applies to the SOFR rate itself; for old LIBOR loans that fell back to SOFR it applies to SOFR plus the adjustment. With SOFR near 3.7% in 2026, floors of 0% or 0.50% do not bite, but the clause still has to be read right for the day they do.
SOFR has stayed far above common floors since 2023, and prime has followed it down
Quarterly averages, January 2023 to September 2026, percent
Real rates, for scale: SOFR was 3.62% on September 16, 2026 and 3.85% the next day, after the Federal Reserve's September move; the prime rate went from 6.75% to 7.00% on September 17.15,10 The example's sample Term SOFR fixings, 3.79% to 4.12%, are the product of a fictional rate history and are used only inside the example.
How a floor is applied
New SOFR loans
The floor sits under the benchmark
"For new loans, it is recommended that any interest rate floor apply to the SOFR Average or Term SOFR."4 For SOFR in arrears, "the floor be calculated daily and not at the end of an interest period".3 Kestrel's agreement deems Term SOFR below 0.50% to be 0.50%; its lowest sample fixing, 3.86192%, never came close.
Old LIBOR loans
The floor sits under SOFR plus the adjustment
For legacy loans the ARRC reads the floor as applying to SOFR plus the spread adjustment. Its own example: a 0% LIBOR floor and a 25 basis point adjustment give a SOFR floor of minus 25 basis points.3,4 Apply the floor to SOFR alone and the borrower pays more whenever rates are low.
The spread adjustments
The fixed spread adjustment grows with the tenor it replaces
Added to SOFR in legacy LIBOR loans that fall back under the ARRC language or the LIBOR Act, percent
The adjustments are the five-year median gap between LIBOR and SOFR, fixed on March 5, 2021.4,16 New loans priced on SOFR often carried an adjustment of their own while the market moved off LIBOR.
In 100 credit agreements LexisNexis reviewed from May to mid-October 2022, none used the ARRC's tenor-based values as such, 13 used some tenor-based adjustment, 8 had none, and "most deals analyzed used a flat credit spread adjustment of 0.10%"; the benchmark floor "typically is 0%".17 We found no published count for 2025 or 2026. Whatever the deal chose, it is one more line in the rate build: fixing, plus any adjustment, floored as the agreement says, plus the margin.
09 · Fees and their base
Unused line, letter of credit, fronting and agency fees: the base each one is charged on
In shortA commercial loan's fees use the same arithmetic as its interest, on a different base. The unused line fee is charged on the commitment less whatever the agreement counts as used. The letter of credit fee is charged on the amount that could be drawn under each letter. The rate is rarely disputed; the base is, because it depends on definitions and on the day each transaction lands.
Fee
Charged on
Typical wording in filed agreements
Who receives it
Unused line (commitment) fee
Daily commitment less loans and, usually, letters of credit
0.10% to 0.50% a year in sample clauses; one counts "the undrawn amount of letters of credit" as usage; one is "computed on the basis of a 360-day year, actual days elapsed".18
Revolving lenders, by share
Letter of credit fee
"the daily maximum amount available to be drawn"
The Applicable Rate for revolving loans, paid quarterly in arrears to each lender "in accordance with its Pro Rata Share".19
All revolving lenders
Fronting fee
The amount available under each letter of credit
"Fronting Fee Rate means an amount equal to 0.125% per annum."20
The issuing bank only
Agency fee
Usually a fixed yearly amount
Set in a separate fee letter, so the check needs the fee letter as well as the agreement.
The administering bank
Kestrel Ridge's unused line fee for the third quarter, band by band
Kestrel Ridge's line is $15,000,000, its fee 0.30% a year on the daily unused amount, and the agreement counts loans and letters of credit as used. A standby letter of credit of $750,000 was outstanding all quarter. Each time the loans changed, the unused amount changed, so the quarter splits into three bands:
Band
Unused amount
Days
Fee
Jul 1 – Aug 13
$15,000,000 − $2,880,000 loans − $750,000 letter of credit = $11,370,000
44
$11,370,000 × 0.30% × 44 ÷ 360 = $4,169.00
Aug 14 – Sep 17, after the $1,250,000 draw
$15,000,000 − $4,130,000 − $750,000 = $10,120,000
35
$10,120,000 × 0.30% × 35 ÷ 360 = $2,951.67
Sep 18 – Sep 30, after the $600,000 repayment
$15,000,000 − $3,530,000 − $750,000 = $10,720,000
13
$10,720,000 × 0.30% × 13 ÷ 360 = $1,161.33
The quarter
92
$8,282.00
Leave the letter of credit out and the fee rises by $750,000 × 0.30% × 92 ÷ 360 = $575.00 for the quarter. In the same fictional run another borrower's fee had been charged on its line less loans only, though its agreement counted $2,400,000 of letters of credit as usage: $2,400,000 × 0.50% × 92 ÷ 360 = $3,066.67 too much. The letters had been moved to a separate account when the facility was amended.
Why the undrawn half matters
About half of every large shared commitment is undrawn, and that half is what unused fees are charged on
Shared National Credits ($100 million or more, held by several regulated lenders), committed amounts by year
The 2025 review counted $6,911.4 billion of commitments to 6,857 borrowers, $3,362.4 billion of it drawn.21 Regulators treat an unused commitment as an exposure in its own right: the Call Report counts "Commitments for which the bank has charged a commitment fee or other consideration", "regardless of whether they contain 'material adverse change' clauses".22 The fee is the price of that exposure, and a base that is wrong by one letter of credit is wrong every day the letter is outstanding.
10 · Default interest and late charges
Default interest and late charges: the day they start, the day they stop, and the state limits on both
In shortDefault interest is the ordinary arithmetic with a higher rate, most often 2% a year above the normal rate. What decides the charge is the count of days: when the higher rate starts (on the default, on notice, or when the lender elects) and when it stops (cure, waiver, payment). Late charges turn on the grace period. State law can strike either one, and California courts have struck charges measured on the whole loan balance.
The common formulation in filed agreements adds two points: "a rate per annum equal to two percent (2%) in excess of the rate otherwise applicable thereto", or "the interest rate (including any Applicable Rate) otherwise applicable to such Loan plus 2% per annum".23
The start is where the agreements differ. Some apply the default rate automatically from the Event of Default. Some apply it from written notice, often the day after. Some leave it to the lender's election in the notice. The notices clause then decides what counts as notice: personal delivery, courier, registered mail, sometimes email to a named address, and when each is deemed given.
One default, two start dates
The default rate ran from the day after the courier notice, so August had 14 days of it
A fictional dairy cooperative's August default interest, at 2.00% on $8,920,000
Aug 11Email sent
A servicing officer emails the cooperative's former finance chief. The notices clause requires courier or registered mail.
Aug 11System starts the default rate
The loan system begins charging from the email date: 21 days, $10,406.67.
Aug 17Courier notice signed for
The notice the clause requires is received.
Aug 18Default rate starts
The day after notice: 14 days to August 31, $6,937.78.
Sep 28Borrower disputes all of it
Partly right: $3,468.89 is credited. The covenant breach, coverage of 1.08x against 1.20x, was a continuing default.
Fictional example from this guide
Show the numbers
When
What
Aug 11
Email sent
Aug 11
System starts the default rate
Aug 17
Courier notice signed for
Aug 18
Default rate starts
Sep 28
Borrower disputes all of it
The borrower asked for every dollar back. It was right about the email and wrong about the rest: a covenant default continues until it is cured, waived or amended away, and a borrower can be current on every payment while its fixed charge coverage is below the agreement's minimum. A yes-or-no answer would either refund money the bank was owed or refuse a credit the borrower was owed. The arithmetic gives the answer:
Start date
Days to Aug 31
Default interest
Billed: Aug 11, the email
21
$8,920,000 × 2.00% × 21 ÷ 360 = $10,406.67
Owed: Aug 18, the day after the courier notice
14
$8,920,000 × 2.00% × 14 ÷ 360 = $6,937.78
Credit to the borrower
7
$3,468.89
The stop date matters as much. In the same fictional run, a vineyard's default was waived effective September 25, and its agreement stops the default rate when a default is "cured or waived". The loan system left it running to September 30: $1,912,500 × 2.00% × 5 ÷ 360 = $531.25 too much.
Late charges turn on the grace period in the same way. A freight company's agreement charges 5% of an installment "not received within 10 days after its due date"; the September 1 installment of $17,300.00 arrived September 9, and the system, set up with no grace period, charged $865.00 anyway.
Where the law limits the charge
Rule
What it says
What it means for the bill
California: Garrett (1973)
A late charge "measured against the unpaid balance of the loan must be deemed to be punitive in character". The note charged 2% a year extra on the unpaid principal while an installment was late.13
A charge on the whole balance for a missed installment is open to challenge under California law.
California: Honchariw (2022)
A $5.6 million commercial bridge loan: a 10% late fee on a $39,667 payment and 9.99% default interest on the balance were an unlawful penalty; the California Supreme Court denied review.8
Default interest needs "a reasonable relationship to the lender's actual damages" in a California-law loan.8
New York usury
No civil rate limit on loans of $250,000 or more, except loans secured mainly by a one- or two-family home; no limit at all, criminal included, at $2.5 million or more.12 Criminal usury below that starts above 25% a year.24
A default rate stacked on a high rate on a smaller loan needs a usury check.
National banks
"Interest" under 12 U.S.C. 85 includes "late fees".11
A national bank's late fees follow the same rate rules as its interest.
No federal disclosure rule shapes the charge; the agreement and state law do.
A summary for orientation; take legal advice on your own loans. Which state's law applies depends on the agreement's choice of law and on who the lender is.
11 · Accrual periods and rounding
Splitting a quarter at every draw, repayment, reset and pricing change, then rounding as the agreement says
In shortA quarter is billed as a string of accrual periods, each with one balance and one rate. A new one starts whenever money moves, a benchmark resets, a margin steps after a compliance certificate, or a prime-based rate changes. Then each period is rounded the way the agreement or the bank's written rule says. Getting either step wrong moves the bill by dollars, and by more on large loans.
One quarter, ten accrual periods: every draw, repayment and reset starts a new line
Kestrel Ridge Foods, July 1 to September 30, 2026, by day of the quarter
Term loanRevolving loansUnused line fee
Term loan · Jul 1 – Aug 31
Term loan · Sep 1 – 30
Revolver · Jul 1 – Aug 2
Revolver · Aug 3 – 13
Revolver · Aug 14 – 31, after the draw
Revolver · Sep 1 – 17, new fixing
Revolver · Sep 18 – 30, after the repayment
Unused fee · Jul 1 – Aug 13
Unused fee · Aug 14 – Sep 17
Unused fee · Sep 18 – 30
Jul 1Aug 1Sep 1Sep 30
Fictional example from this guide
Show the numbers
Activity
From
To
Term loan · Jul 1 – Aug 31
0
62
Term loan · Sep 1 – 30
62
92
Revolver · Jul 1 – Aug 2
0
33
Revolver · Aug 3 – 13
33
44
Revolver · Aug 14 – 31, after the draw
44
62
Revolver · Sep 1 – 17, new fixing
62
79
Revolver · Sep 18 – 30, after the repayment
79
92
Unused fee · Jul 1 – Aug 13
0
44
Unused fee · Aug 14 – Sep 17
44
79
Unused fee · Sep 18 – 30
79
92
Four events that start a new period
Money moves
Draws, repayments, amortization
The agreement says whether the day money moves earns interest at the old or the new balance. Kestrel's $1,250,000 draw counts from August 14, the day it was funded.
The benchmark resets
A new interest period
Each Term SOFR period has its own fixing. Prime-based loans reset on the day prime changes, if the agreement says so.
The margin steps
A pricing grid moves
A compliance certificate showing lower leverage can cut the margin from the next business day. In the fictional run, a dental group's certificate of Friday, August 14 cut its margin from 2.75% to 2.50% from Monday, August 17; the system kept 2.75%, $2,015.63 too much.
A default starts or ends
The default rate switches
On notice, cure or waiver, as section 10 showed.
A real split in the third quarter of 2026
The prime rate rose from 6.75% to 7.00% on September 17, 2026.10 Take an illustrative $1,000,000 loan at prime plus 1.00%, Actual/360, whose rate adjusts on the day prime changes. The quarter splits into two accrual periods:
Period
Days
Rate (prime + 1.00%)
Interest
Jul 1 – Sep 16
78
6.75% + 1.00% = 7.75%
$1,000,000 × 7.75% × 78 ÷ 360 = $16,791.67
Sep 17 – Sep 30
14
7.00% + 1.00% = 8.00%
$1,000,000 × 8.00% × 14 ÷ 360 = $3,111.11
Quarter, split correctly
92
$19,902.78
Quarter, never split
92
7.75% throughout
$19,805.56, or $97.22 short on every million
Real figures for the prime rate; an illustrative loan.
Rounding to the cent: once per accrual period or once per bill
The ARRC recommends that SOFR rates be "rounded (not truncated) to 5 decimal points and dollar amounts be rounded to 2 decimal points" on invoices and reports, with no rounding inside the calculation itself.3
Rounding each accrual period to the cent and rounding once per bill give different totals, a cent or two each time, which is enough to make a reconciliation fail. When the agreement is silent, the bank's own written rule decides, and the check has to use the same one or every bill will show a false difference.
12 · Participations and agency notices
Agency notices and participant shares: checking what the administering bank says each lender is owed
In shortIn a shared loan, one bank administers the facility: it sets the rate, collects the interest and pays each lender its share. Each lender is owed interest on its share for each day it held it. A share bought mid-period earns the new percentage only from the recorded effective date. Lenders that check the administering bank's notices against the agreement catch short payments; those that do not, rarely do.
A participant's interest passes through four checks between the borrower and its own books
1Rate set notice
The administering bank announces the period's rate: the fixing, any adjustment, the margin.
Agency bankPeriod start
2Borrower pays
Interest for the period, on the whole loan.
BorrowerPayment date
3Distribution
Each lender's share by day, from the register of holdings.
Agency bankSame day
4Reconcile
Rate, days, balance and share checked against the agreement and the notice.
Each lenderWithin days
5Claim or close
A short payment is raised with the figures; a match is closed.
The administering bank announces the period's rate: the fixing, any adjustment, the margin.
Agency bank
Period start
Borrower pays
Interest for the period, on the whole loan.
Borrower
Payment date
Distribution
Each lender's share by day, from the register of holdings.
Agency bank
Same day
Reconcile
Rate, days, balance and share checked against the agreement and the notice.
Each lender
Within days
Claim or close
A short payment is raised with the figures; a match is closed.
Each lender
As needed
The ARRC's convention is the market's: "daily accrued interest is calculated on each lender's share of principal that day", and a lender that sells out "is owed interest based on the time they held part of the loan".3 Examiners expect the buyer of a participation to keep watching: "During the life of the participation, the participant should monitor the servicing and the status of the loan."25
A share that changed mid-month, worked
In the example's inbox, a bank that bought an extra 2.5% of an apartment loan wrote that its share was now 22.5% and asked for $1,030.15 more of September's $41,206.18 of interest, which is 2.5% of the whole month. The assignment was recorded effective September 15, so the month splits at that date. September's interest accrues evenly over its 30 days:
Days
Share
The participant's interest
Sep 1 – Sep 14 · 14 days
20%
$41,206.18 × 20% × 14 ÷ 30 = $3,845.91
Sep 15 – Sep 30 · 16 days
22.5%
$41,206.18 × 22.5% × 16 ÷ 30 = $4,944.74
Owed for September
$8,790.65
Paid, at 20% for the whole month
$8,241.24
Still owed
$549.41, against $1,030.15 claimed
The participant was right about the share and wrong about the dates.
When the administering bank gets it wrong. On August 11, 2020, Citibank, acting for the lenders on a Revlon term loan, meant to pay about $7.8 million of interest and instead paid off the whole $894 million loan, which was not due until 2023.26 About $400 million came back. The rest, about $500 million, stayed frozen by court order while some lenders fought to keep it. On September 8, 2022 the Second Circuit ruled that they had been on notice of the mistake and could not keep the money under the discharge-for-value rule.27,26 The mistake sat in a payment instruction, and the fight over it lasted two years.
13 · How bills go wrong
Nine ways a commercial loan bill goes wrong, and the document where each one starts
In shortAlmost every billing error is a set-up error: a term keyed differently from the agreement, a default left in place, an event that never reached the system. Each produces the same wrong figure every period until someone recalculates. The example's billing run shows seven of them in one morning.
Six causes, seven bills: the unused fee base and the day count lead one morning's differences
The seven bills in the fictional third-quarter run that differ from their recalculation by more than $1.00
Unused fee base: letters of credit left out$3,067
Day count: 30/360 note billed Actual/360$2,692
Margin step-down not applied$2,016
Day count, second loan from the same conversion$1,184
Late charge inside the grace period$865
Default interest after a waiver$531
Fixing read on the wrong day (underbilled)$413
Fictional example from this guide · Rounded to the dollar. $10,354.30 overbilled on six bills and $412.66 underbilled on one, out of $38,614,287.40 billed on 412 bills.
Show the numbers
Item
Value
Unused fee base: letters of credit left out
$3,067
Day count: 30/360 note billed Actual/360
$2,692
Margin step-down not applied
$2,016
Day count, second loan from the same conversion
$1,184
Late charge inside the grace period
$865
Default interest after a waiver
$531
Fixing read on the wrong day (underbilled)
$413
Error
Where it starts
How it shows
The check that catches it
Wrong day count
Boarding or a system conversion on the bank's default
Extra days in 31-day months
Day-count clause per facility, against the set-up
Wrong fixing date or calendar
"Two business days" stored as calendar days, or the first day of the period
A real rate, for the wrong day
Each period's fixing date worked out from the clause
Floor applied wrongly
Floor tested at period end, or before the adjustment on a legacy loan
Only when rates are low
Daily floor test as the clause words it
Margin not stepped
A compliance certificate filed but not keyed
The old margin after the step date
Pricing grid against each certificate's date
Fee base wrong
Letters of credit or swingline left out; a commitment cut not keyed
A fee too high every day
The usage definition, rebuilt by day
Default rate on the wrong dates
An email taken as notice; a waiver never keyed
Days at the default rate that should not be
Notice, cure and waiver dates from the correspondence
Late charge in the grace period
Grace period set to zero
A charge on a timely payment
Payment date against due date plus grace
Participant share for the whole period
New share applied from the first of the month
One lender over, another short
Shares by day from the recorded effective date
Rounding mismatch
Per-bill rounding where the rule says per period
A cent or two, every bill
One written rounding rule, used by both sides
14 · Errors on the record
Interest errors that reached courts and regulators, from Anglo Irish Bank's borrowers to Revlon's lenders
In shortInterest calculation errors do reach the record, and when they do they are large because they repeat. A misread interest term at one Irish bank touched 6,435 borrowers. A US consumer regulator found improper interest and fees across millions of auto loans. In a survey run by a calculation software vendor, more than two-thirds of the lending and fintech organizations that answered said they see payment discrepancies every week or month. No public source counts commercial billing errors in the US.
€100M
of overcharged interest, by estimate, to be repaid to 6,435 borrowers on 15,571 accounts, after a 2011 court finding that the former Anglo Irish Bank misread interest terms common to most of its commercial loans.28
The Irish Times, November 2016
$1.3B
of redress ordered for auto loan servicing failures at Wells Fargo across more than 11 million accounts, including improperly charged fees and interest.29
CFPB, December 20, 2022
$894M
loan paid off by mistake by the bank administering it, which meant to send Revlon's lenders a $7.8 million interest payment.26
Reuters, September 8, 2022
What lenders say about their own calculations
Fees and rate application lead the causes respondents give for calculation errors
Share of respondents naming each cause, survey of more than 2,000 lending, banking, auto finance and fintech staff, 2025
Only 14 in 100 respondents say their tools handle complex loans well
14 in 100
respondents who said their current tools handle tiered rates, variable payment schedules and other complex structures without trouble
Source30 · Survey run by Carleton, a vendor of loan calculation software, of lending, banking, auto finance and fintech staff, including loan software vendors.
Show the numbers
Measure
Value
respondents who said their current tools handle tiered rates, variable payment schedules and other complex structures without trouble
14 of 100
The same survey found "more than two-thirds of organizations experience loan payment discrepancies weekly or monthly", that 60% struggle to keep their systems in line with rule changes, and that 44% rate their confidence in their systems at only one or two.30,31
It was run by a company that sells calculation software; its respondents came from banks, credit unions, mortgage, auto finance and fintech lenders, and nearly a quarter worked for loan software vendors, with no split for commercial lending.31 Treat it as a sign of the problem and measure your own book.
15 · What a wrong bill risks
What a wrong bill puts at risk: refunds, the borrower's trust, participant claims and exam findings
In shortAn overbill is paid back with an apology; a repeated one costs the relationship and, if it spreads across a book, a remediation program. An underbill is lost income for the bank and for every participant. Both weaken the bank's position in a dispute, because the bank's defense is that it billed what the document says.
The errors that hurt most are the ones nobody outside the bank will report
Where common billing errors sit: how often they repeat against how likely the borrower is to find them
Borrower likely to notice →
Noticed, but rare
Noticed and repeating
Quiet and rare
Quiet and repeating
Day countLate charge in graceFee baseParticipant shareFixing-date underbill
Repeats on every bill →
Illustrative · replace with your own numbers · Positions are our judgment from the worked examples (default interest after a waiver sits with late charges); no public data ranks commercial billing errors.
Show the numbers
Item
Repeats on every bill (0–1)
Borrower likely to notice (0–1)
Day count
0.80
0.60
Late charge in grace
0.12
0.72
Fee base
0.80
0.22
Participant share
0.12
0.30
Fixing-date underbill
0.70
0.10
The borrower
Refunds and trust
A controller who finds two extra days in July asks what else is wrong. Every credit raised after the fact costs more staff time than a bill held and corrected before it went out, and it arrives with a request to see the arithmetic.
The participants
Claims both ways
Banks that bought shares are owed interest by day and are expected to watch the servicing.25 An underbill shorts them; an overbill refunded later has to be clawed back from them.
The examiners
A servicing finding
Repeated errors across loans boarded the same way point to a control gap at boarding or conversion. Across a book, as at the Irish bank, they become a remediation program.28
The model inventory
Which rules apply
SR 26-2 excludes "simple arithmetic calculations" and "deterministic rule-based processes" from its definition of a model, and puts generative AI, and AI that takes actions on its own, outside its scope, leaving both to each bank's own governance.9
16 · The market
$2.96 trillion of business loans and $6.9 trillion of shared credits, billed on floating rates with no public error count
In shortUS banks held $2,959 billion of commercial and industrial loans in September 2026. Shared National Credits, the largest syndicated facilities, reached $6.9 trillion of commitments in 2025, up 43% in six years. Most of that money is billed on floating rates with the conventions described above. Nobody publishes how often those bills are wrong.
Large shared commitments grew by $2.1 trillion between 2019 and 2025
Commercial and industrial loans at all US commercial banks were $2,958.98 billion in September 2026, seasonally adjusted.32 The Shared National Credit review covers loans of $100 million or more shared by several regulated lenders: 6,857 borrowers and 11,952 facilities in 2025, with $6,911.4 billion committed and $3,362.4 billion drawn.21,33 Behind those totals are thousands of smaller bilateral loans at community and regional banks, each with its own agreement and its own set-up.
What nobody publishes. We found no regulator, trade body or study that measures the share of commercial loan bills that are wrong, the dollars involved, or the time servicers spend on disputes. The figures in this guide's example are fictional. Your own run is the only baseline you can defend: recalculate a sample of last quarter's bills and count.
17 · What software can check
Recalculating a loan bill is exact arithmetic; reading the agreement is where AI helps and where its output must cite the clause
In shortRecalculating a bill is arithmetic, and software can do it exactly for every bill in a run. The harder part is reading the terms out of the agreement and its amendments, which is where AI reading tools help and where their output has to show the clause it came from. Deciding whether to rebill, credit, answer a dispute or change a system set-up stays with people.
Task
Kind of work
What a good tool shows
Who decides
Read the pricing and fee terms
Reading documents, amendments in date order
Each term with its clause and page; conflicts between amendments flagged
A person confirms anything unclear
Collect the rate fixings
Rules: fixing date from the clause, published value
The date, the source and the value; a missing fixing stops the calculation
Nobody guesses a rate
Rebuild every accrual period
Deterministic arithmetic
Days, balance, rate, basis, amount, rounding, per line
Not needed for the arithmetic
Explain a difference
Compare against the system's set-up
The term that differs, proven by reproducing the system's figure
The servicing officer reviews
Rebill, credit, answer, change the set-up
Judgment and authority
The draft with its figures
The officer signs; a supervisor above a limit
The April 2026 model guidance helps sort the pieces. A deterministic recalculation is outside its definition of a model. An AI reader of agreements is outside its scope, so the bank's own governance applies, as SR 26-2 says it should "for any tools, processes, or systems not covered".9 In practice that means evidence for every term read, a person signing every letter and credit, and a test on the bank's own agreements before trusting the reader on new ones.
The limits. A reader can misread a clause, especially one amended twice. A rate source can be late or revised. A system's set-up can differ in ways a bill does not reveal until rates move. The defense against all three is the same: show the clause, the fixing and the arithmetic on every line, and let the difference prove itself by reproducing the system's figure to the cent.
18 · How teams do it today
A commercial loan billing dispute handled by hand today: the borrower's letter, the analyst's spreadsheet and the officer's signature
In shortMost banks send what the loan system computes and investigate when a borrower or participant complains. Then a billing analyst gathers the agreement, its amendments, the rate history and the transactions, rebuilds the period in a spreadsheet, finds the cause, and hands the answer to a servicing officer to sign. One dispute can take most of a working day.
The five people around a disputed bill
BA
Billing analyst
Runs the billing cycle and rebuilds disputed bills from the documents.
Cares about: one dispute not eating a whole day.
SO
Loan servicing officer
Owns the servicing of a set of relationships; signs corrections, credits and answers.
Cares about: not hearing about an error from the borrower first.
AS
Agency and participations staff
Send rate and payment notices, pay participants their shares, answer their claims.
Cares about: the day a share changed.
LS
Loan operations supervisor
Second signature on larger credits; approves changes to a loan's system set-up.
Cares about: the clause, the rate and the arithmetic on one page.
BC
The borrower's controller
Re-computes the bank's bills, or should.
Cares about: paying what the agreement says.
From the controller's letter to a signed answer, hand-off by hand-off
A disputed bill passes through three people and four document sources before an answer goes out
1Dispute arrives
A letter or email from the borrower's controller or a participant.
Rates for every reset, transactions, accrual periods in a spreadsheet.
Billing analyst
Hours
Cause found
The term where the system and the agreement part.
Billing analyst
An hour or more
Answer signed
Correction, credit or reasoned reply; set-up change requested.
Servicing officer, supervisor
Days later
Where a day of rebuilding one bill goes
Rebuilding the accrual periods takes the longest part of a disputed bill
An estimated split of eight hours for one disputed commercial bill rebuilt by hand
Rebuilding every accrual period in a spreadsheet2.5 h
Finding the agreement, amendments and pricing terms1.5 h
Rebuilding draws, repayments and letters of credit1.5 h
Looking up the rate fixings for every reset1 h
Finding the term that caused the difference1 h
Writing the answer or the correction0.5 h
Illustrative · replace with your own numbers · An estimate; no public time study exists. Time your own next three disputes.
Show the numbers
Item
Value
Rebuilding every accrual period in a spreadsheet
2.5 h
Finding the agreement, amendments and pricing terms
1.5 h
Rebuilding draws, repayments and letters of credit
1.5 h
Looking up the rate fixings for every reset
1 h
Finding the term that caused the difference
1 h
Writing the answer or the correction
0.5 h
Trust the system, keep shadow spreadsheets, outsource, or recalculate every bill
Trust the system
Investigate complaints
Bills go out as computed. Cheap until a set-up error repeats across a conversion batch; finds overbills only, and late.
Shadow spreadsheets
Re-compute the complex deals
Analysts keep workbooks for syndicated or unusual loans. Catches more; depends on who built each workbook and whether it was updated after the last amendment.
Outsource
Loan administration services
A third party administers and bills. Moves the work; the bank still owns the result and has to check it.
Recalculate every bill
Independent check software
Every bill rebuilt from the agreement and the published rates before it is sent; differences held with their cause. The subject of Part C.
Part B · See it working
Loan interest and fee recalculation in Botminds: 412 quarterly bills checked against their agreements before the 4:00 p.m. send
Part A described the work without naming a product. This part shows how Botminds does it, at a fictional regional bank on the morning its third-quarter bills are due out. Every borrower, person, rate fixing and figure on the screens is sample data.
19 · One billing run
Two extra days on a 30/360 term loan, caught before the send: the Kestrel Ridge Foods bill from recalculation to signed correction
In shortThis is the example from the top of the page, inside the product. Six agents recalculate all 412 bills of Tallowmere Bank's third-quarter run from their agreements before the send. Seven differ and are held. Renée Castillo, the loan servicing officer, opens the largest as a receipt, sees the clause and the arithmetic behind the wrong line, proves the cause by replaying the system's set-up, and signs the correction. Gail Sorensen co-signs because the credit is above $2,500.
1
All 412 bills, recalculated before they go out
Between 9:09 and 9:12 a.m. on Thursday, October 1, the agents recalculate every bill the core loan system printed that morning, each from its own agreement and the published rates. 405 agree within the $1.00 tolerance and are ready for the 4:00 p.m. send. Seven differ: $10,354.30 overbilled on six bills, $412.66 underbilled on one.
Each held bill carries its cause in plain words: day count, unused fee base, margin step-down, late charge, default interest, fixing date. Marcus Feld, the billing analyst, can send the 405 that agree with one confirmation.
The billing run. The run's totals across the top, then the seven bills that differ, each held with its cause, before the 4:00 p.m. send.
2
The bill as a receipt, line by line
Renée opens Kestrel Ridge Foods, Loan 4471. The bill prints as a recalculation receipt: every accrual period with its days, balance, rate, basis, the recalculated amount, what the system billed and the difference. The August 14 draw, the September 1 amortization and the September 18 repayment sit on their own lines where they change the balance.
Each line carries chips for its clause, such as §2.4(c), and for the Term SOFR fixing behind it. One line is red: the term loan, July 1 to August 31, $2,691.55 over.
The recalculation receipt. Every accrual period with its clause and fixing, the system's amount beside it, and the difference panel explaining the one line that is wrong.
3
One line, with its clause and its arithmetic
She clicks the red line. Section 2.4(c) of the amended and restated agreement, page 32: "Interest on the Term Loan shall be computed on the basis of a 360-day year consisting of twelve 30-day months." Below it, the arithmetic written out both ways.
Recalculated: 7,814,177.42 × 6.20% × 60 ÷ 360 = 80,746.50. Billed by the core system: the same balance and rate × 62 ÷ 360 = 83,438.05. The rate and the balance agree; only the days differ.
One line, opened. The two clauses behind the line and the arithmetic, recalculated against billed.
4
The cause, proven by replaying the system's set-up
Renée switches on "Replay as the system billed". The receipt re-runs with the core system's day count on the term loan, Actual/360, which the bank calls 365/360. The line moves to 62 days and the difference falls to $0.00 on every line: the replay reproduces the bill to the cent, $186,904.10.
Nothing else on the bill differs, so the cause is proven. The same set-up overbilled the second quarter by $1,378.07, already paid on July 1.
Replay as the system billed. The same receipt under the system's set-up reproduces the bill to the cent: the proof that the day count, and only the day count, is wrong.
5
The correction, two signatures, and the set-up fixed
The drafter prepares the corrected statement and the letter to Tessa Lindqvist, the borrower's controller: the third quarter rebilled at $184,212.55, less the $1,378.07 second-quarter credit, $182,834.48 due October 15. The statement printed that morning for $186,904.10 is never sent.
The credit in all, $4,069.62, is above Renée's $2,500 limit, so after she signs, Gail Sorensen, the loan operations supervisor, co-signs and approves the day-count change on Loan 4471 and on Loan 5208, Marlowe Street Partners, the one other note among the 38 converted on April 3 that says 30/360.
The signed correction. The letter, the corrected statement with the prior-quarter credit, the set-up change for two loans, and both signatures.
The solution's design estimate is about 15 minutes to answer a disputed bill, against half a day to two days rebuilt by hand, and its design target is 100% of bills recalculated before every send. Both are to be measured on your own run.
20 · Every screen
The rest of the billing morning on screen: a wrong fixing date, an unused fee base, a missed margin step, a late charge and two disputes
In shortKestrel Ridge is one bill. These screens show the rest of the morning: the receipt's stamped total, the terms set against the system's set-up, the rate history with a wrong fixing caught, the receipts for an underbill, a fee base, a margin step and a late charge, the disputes inbox with a borrower's and a participant bank's claims answered, and the settings.
The stamped total. The unused fee's three bands, the checks recorded as not applying (the 0.50% floor never reached, no default interest, the letter of credit counted as usage), the total, and each agent's step in the run.
Loan terms against the set-up. Each pricing and fee term read from the agreement with its clause, beside the core system's set-up: eleven match, the term loan day count differs. The agreement's own text runs down the right.
Rate history. One-month Term SOFR as published in the sample data, the fixings each period used, the floor test, and the September 1 fixing used for one loan by mistake. The fixings are fictional; real SOFR is in section 08.
An underbill from the fixing date. Ostrander Tool & Die's September period priced on the fixing published September 1 instead of two business days before the period: $412.66 too low, held all the same.
The unused fee base. Wrenhallow Senior Living's fee charged on $5,900,000 unused; its agreement counts $2,400,000 of letters of credit as used, so the base is $3,500,000.
A late charge inside the grace period. The September 1 installment arrived September 9, inside the ten-day grace period to September 11, so the $865.00 charge comes off.
A pricing grid step not applied. Gorsefield Dental Group's compliance certificate, delivered August 14, cut the margin to 2.50% from August 17. The system kept 2.75%; two lines are over by $2,015.63.
Disputes. Bills questioned by borrowers and participant banks, each with the claim, the verdict, the amount owed and its status.
A borrower's dispute, claim by claim. Bellhaven Dairy Cooperative is right that the email was not notice and wrong that the default ended: 14 days at the default rate where the system billed 21, and a $3,468.89 credit drafted for signature.
A participant bank's claim. Cobalt Prairie Bank's larger share counts from the assignment's recorded date, September 15: 14 days at 20% and 16 at 22.5%, so $549.41 is owed of the $1,030.15 claimed.
Your servicing rules. Tolerance, hold rule, when to recalculate, the rounding default when an agreement is silent, rate sources, signing limits; every change saved as a new rule version.
Click any screen to open it larger. The bank, borrowers, people, rates and figures are fictional.
21 · Agents, and who signs
Arithmetic by software, signatures by people: the agents behind each receipt and the $2,500 co-signing limit
In shortEach agent has one job and limits it does not cross. The calculator does arithmetic only, and the system's billed amount is never one of its inputs. A difference is explained only when replaying the system's set-up reproduces the bill. No agent sends a bill, a credit or a letter; a person signs every one.
What each agent does, and the line it never crosses
Agreement terms reader
Reads the pricing and fee terms from the credit agreement and its amendments in date order: margin, index, floor, fixing date, day counts, fees, default rate, payment dates, each with its clause and page.
Never fills a term the documents do not state; flags conflicts between amendments.
Rate fixing collector
Works out each fixing date the agreement defines, takes the published Term SOFR or prime value for it, and tests the floor.
Never estimates or interpolates a rate; a missing fixing stops the calculation.
Transaction reader
Reads draws, repayments, amortization, letters of credit and payments from the loan's transaction history.
Never uses the system's billed interest as an input.
Independent calculator
Splits the period wherever the balance or the rate changes and rebuilds every accrual period: days under the agreement's day count, balance, floored rate, amount, rounded as the agreement says.
Never produces a number by anything but deterministic arithmetic.
Difference explainer
Compares the recalculation with the system's bill line by line, finds the term whose set-up differs from the agreement, and replays the system's set-up to reproduce the bill.
Never closes a difference it cannot reproduce to the cent.
Dispute and letter drafter
Reads borrower and participant disputes, lists and checks each claim against the agreement and the recalculation, and drafts the answer or the correction with the figures.
Never sends a letter or a credit; a person signs every answer.
Who holds, who signs, who co-signs and who sends
Decides and signsLoan servicing officerHolds, corrects and rebills, answers disputes, and signs credits up to $2,500. Releasing a held bill uncorrected needs a written reason the supervisor sees.
Second signatureLoan operations supervisorCo-signs credits above $2,500 and approves every change to a loan's system set-up, which loan operations then applies.
Runs the cycleBilling analystSchedules the runs, sends the bills that agree, and exports the run with the receipts for those that differ.
Every hold, release, signature and agent step is recorded with its time. Each receipt records the agreement version, the fixings and the transactions it used, and every settings change is saved as a new rule version.
The Tallowmere Bank team and the borrower's controller in the screens
Fictional, from the sample data
RC
Renée Castillo · loan servicing officer
Owns the servicing of 140 commercial loans; signs bills, credits to $2,500 and dispute answers.
"I don't want to find out from the borrower's controller."
MF
Marcus Feld · billing analyst
Runs the quarterly billing; used to rebuild every disputed bill in a spreadsheet.
"Every dispute is a day of rebuilding a spreadsheet."
OA
Owen Adeyemi · agency services associate
Pays participant banks their share of interest and fees.
"When a participant says we shorted them, I need the day the share changed."
GS
Gail Sorensen · loan operations supervisor
Co-signs credits above $2,500 and approves set-up changes.
"Show me the clause, the rate and the arithmetic, then I'll sign."
TL
Tessa Lindqvist · controller, Kestrel Ridge Foods
Re-computes every bank bill herself.
"Your 30/360 note doesn't bill 62 days for July and August."
22 · What goes in and out
From signed agreements and published fixings to a receipt for every bill: the data the recalculation reads and the records it keeps
In shortThe solution reads what the bank already has: the agreements, the published rates, the loan system's bills and transaction history, and the disputes. It leaves behind a receipt for every bill with each line's clause and fixing, the cause of every difference, and the drafted correction or answer waiting for a signature. The core loan system stays the system of record; set-up changes are proposed, approved and applied by people.
From your documents and systems
Credit agreements, notes, amendments and fee letters
Compliance certificates, notices and waivers
The loan system's billing run and set-up
Draws, repayments, amortization, letters of credit, payments
Borrower and participant dispute letters
From the market and your policy
Published Term SOFR fixings and the prime rate
Tolerance before a bill is held
Rounding when an agreement is silent
Signing limits and who co-signs
Agents read, recalculate and explainEvery bill in the run, from its own agreement, before it is sent
The servicing officer signs
Every line cites its clause and fixing
Outputs
A recalculation receipt for every bill
Bills that differ held, with the cause named and proven
Corrected statements and letters, ready to sign
Dispute answers, claim by claim
Proposed set-up changes for supervisor approval
The whole run as a spreadsheet export
The servicing, document and market data systems it reads from and hands back to
System
What it exchanges
Core or commercial loan servicing system
The billing run, each loan's set-up and the bills it printed; approved set-up changes go back through loan operations
Document management
Agreements, amendments, fee letters, certificates, notices and waivers
Market data
One- and three-month Term SOFR fixings and the prime rate, under your licenses
Loan accounting and the general ledger
Credits and rebills once signed, through your usual postings
Email and correspondence
Disputes in; signed answers and corrections out
Spreadsheets
The run exported with every receipt that differs
Roles, maker and checker, signing limits, the activity record and every rule version are kept by the platform, so audit and examiners can follow any bill from its agreement to the signature.
Part C · Are you ready to automate?
Interest billing errors, the payback on catching them, and a ten-week test on your own commercial loan bills
You bill commercial loans, or manage the people who do, or answer for the bills when a borrower or a participant bank calls. This part is written for you: what wrong bills cost today, what checking every bill could return, how ready your team is, what to ask any vendor, and how to run a fair test.
23 · What wrong bills cost
Refunds, unbilled interest, dispute days and a controller's patience: where wrong loan bills cost a bank money
In shortStart from your own book. No regulator or study publishes how often commercial bills are wrong, so the numbers that matter are yours: how many bills differ from their agreements, by how much, in which direction, and how long each dispute takes. A sample recalculation of one quarter answers most of it in a week or two.
2 in 3
organizations in a 2025 survey of more than 2,000 lending, banking, auto finance and fintech staff see loan payment discrepancies weekly or monthly. A calculation software vendor ran it.30
Carleton survey, reported September 2025
1.39%
more interest a year from a 360-day year on actual days, the gap a 365/360 set-up adds when the note says otherwise.1
Kreisler v. National City Bank, 8th Cir. 2011
$24/hr
median pay of loan interviewers and clerks in 2025; loan officers' median was $36.87. Add your benefits load for a cost per hour.34,35
O*NET, BLS 2025 wages
Rebuilding a disputed bill by hand takes a day; reading a receipt takes minutes
Minutes for one disputed commercial bill, by hand (eight hours in all) and with every bill recalculated in advance
By handRecalculated in advance
Gather agreement, amendments and rates150 min4 min
Rebuild transactions and accrual periods240 min5 min
Find the cause and write the answer90 min6 min
Illustrative · replace with your own numbers · By hand: an estimate. Recalculated in advance: the solution's design estimate of about 15 minutes. Measure both on your own disputes.
Show the numbers
By hand
Recalculated in advance
Gather agreement, amendments and rates
150 min
4 min
Rebuild transactions and accrual periods
240 min
5 min
Find the cause and write the answer
90 min
6 min
What nobody publishes. There is no public figure for the share of commercial loan bills that are wrong, the average size of an error, the share that are underbills, or the hours a servicer spends per dispute. The survey above covers mostly consumer lending. Every default in the calculator below is marked illustrative for that reason.
Measuring your own error rate, underbills and dispute hours in a week
Cost
Where it hides
How to find your number in a week
Wrong bills
Set-up errors repeating every period
Recalculate 50 bills from last quarter by hand from their agreements; count those that differ by more than $1
Underbills
Errors nobody reports
Of the differences found, the share in the bank's disfavor, and their dollars
Dispute time
Analyst days rebuilding bills; officer time answering
Time your next three disputes from arrival to signed answer
Count last year's billing credits and the hours each one took
Conversion risk
Every loan boarded in one batch on one default
List the batches boarded in the last two years and their day-count defaults
Participant claims
Shares by month instead of by day
Claims from participants in the last year and what you paid
What a wrong bill costs beyond the dollars on it
The controller who stops trusting your billsOnce one bill is wrong, every bill gets re-checked, and the relationship manager hears about it.
The defense you gave awayA bank that bills what its note says wins the 365/360 argument; one that does not has handed the borrower the document.
The participant who sells you outBanks that buy your loans remember who pays them short.
The conversion you cannot unwindA system migration that boards hundreds of loans on one default repeats the error on every one of them.
Your best analyst's weekSpent rebuilding bills a check could have held before they went out.
24 · Your return
The return on recalculating loan bills: underbills recovered, corrections never made, disputes answered from a receipt
In shortPut in your own numbers. The return comes from three places: underbills found and collected, corrections that never have to be made because the bill was right when it went out, and disputes answered in minutes. Overbills caught protect the borrower and the relationship; they are counted separately because the money was never the bank's.
Six places the return comes from, each with its formula
Income
Underbills found
Bills in the bank's disfavor surface only when every bill is checked; borrowers never report them.
bills × error rate × average difference × underbill share
Operations
Corrections avoided
A bill held and fixed before the send needs no credit, rebill, letter or participant true-up afterwards.
bills × error rate × hours per later correction × hourly cost
Disputes
Answers in minutes
The receipt already holds the clause, the fixing and the arithmetic for every line.
disputes × hours saved × hourly cost
Relationships
Overbills never sent
The borrower's controller never finds two extra days in July.
bills × error rate × average difference × overbill share
Conversions
Set-up errors found in a batch
One cause, proven, points to every loan boarded the same way.
loans per batch × share with the same clause
Exams and audit
Evidence on file
Every bill's receipt with its agreement version, fixings and signatures.
hours assembling support for an exam or audit
Put your own billing volume, error rate and hours into the return
No public source publishes commercial billing error rates, so every default here is an assumption to replace. The error rate, average difference and underbill share start from the fictional run in Part B (7 of 412 bills, $10,766.96 in all, one underbill); the hourly cost starts from the 2025 median wages above plus a benefits load. Anything marked illustrative is an assumption.
Your bookYour peopleYour cost
Illustrative yearly value
Bills a year that differ0
Billing differences caught before sending, both ways$0
Underbilled interest and fees recovered$0
Corrections avoided, valued$0
Dispute time released, valued$0
After your yearly cost$0
Formulas, per year: Bills that differ = bills × error rate Differences caught = bills that differ × average difference Underbills recovered = differences caught × underbill share Corrections avoided = bills that differ × hours per later correction × hourly cost Dispute time released = disputes × (hours by hand − hours with recalculation) × hourly cost After your cost = underbills recovered + corrections avoided + dispute time released − yearly cost
Overbills caught are in the second line only: they go back to the borrower, so they protect the relationship and add no income. Not counted: participant claims, exam findings, and the conversion batch where one cause repeats on hundreds of loans.
At the defaults, recovered underbills and avoided corrections outweigh dispute hours
Yearly value at the calculator's defaults, before the tool's cost
Underbilled interest and fees recovered$68.8K
Corrections avoided, valued$55.1K
Dispute time released, valued$41.9K
Illustrative · replace with your own numbers · 18,000 bills, 1.7% differing, $1,500 average difference, 15% underbills, 4 hours per later correction, 120 disputes at 8 hours by hand and 0.25 with recalculation, $45 an hour.
Show the numbers
Item
Value
Underbilled interest and fees recovered
$68.8K
Corrections avoided, valued
$55.1K
Dispute time released, valued
$41.9K
Try three cases. A bank billing 4,000 loan periods a year with 30 disputes and the other defaults comes out about $42,000 short of an $80,000 cost: start with disputes and conversion batches only. At 18,000 bills it clears the cost by about $86,000. At 40,000 bills and 250 disputes it clears it by about $283,000. The error rate drives every line: measure it before you believe any of them.
Start here25 · Readiness check
Score your billing operation out of 16: floating-rate volume, agreements on file, boarding set-ups, disputes and sign-off
In shortPick the answer closest to your team today. Eight questions score 0 to 2; the last is for reflection. The meter adds up your score as you go, and each question says why it matters and what a strong answer sounds like.
1
Volume and complexity
How many floating-rate commercial bills, with draws, fees or more than one facility, does your team send a year?
Why it mattersFixed-rate single loans rarely go wrong once boarded; lines, SOFR resets, fees and pricing grids are where the errors are.
A strong answer"About 1,200 loans, most on Term SOFR, a third with revolvers and letters of credit, billed monthly or quarterly."
2
Your baseline
Do you know how many of your bills differ from their agreements, by how much, and in which direction?
Why it mattersNo public benchmark exists, so your own sample is the only proof of the problem and of any improvement.
A strong answer"We recalculated 50 bills last quarter: three differed, two over and one under, about $4,000 in all."
3
Agreements on file
Can you find the signed agreement, every amendment and every fee letter for each loan, electronically, in one place?
Why it mattersA recalculation is only as good as the documents it reads. A missing amendment produces a confident wrong answer.
A strong answer"In the document system, indexed by loan number, amendments included."
4
Set-up and conversions
Have you boarded or converted a batch of loans in the last two years, and was each loan's set-up checked against its agreement?
Why it mattersA conversion on one default repeats the same error across every loan whose agreement says something else.
A strong answer"We converted 300 loans in 2025 and checked a sample; we know which defaults were applied."
5
Disputes and claims
How often do borrowers or participant banks dispute a bill, and how long does an answer take?
Why it mattersDisputes are the visible cost; their time and their outcome tell you where the hidden ones are.
A strong answer"About ten a month, two days each on average, and a third end in a credit."
6
Systems and data
Can software read your loan system's billing run, set-up and transaction history, and your rate data?
Why it mattersAn export works for a pilot; a scheduled feed lets every run be checked before the send.
A strong answer"A nightly extract of bills and transactions, and a licensed Term SOFR feed."
7
Owner and sign-off
Is there a named owner of billing accuracy, with written signing limits for credits and set-up changes?
Why it mattersHeld bills need someone to release or correct them by the send time; limits become settings.
A strong answer"The head of loan operations owns it; officers sign credits to $2,500, the supervisor above."
8
Governance
Do you have a path to approve AI tools in servicing: vendor due diligence, a view on SR 26-2, human sign-off and an audit trail?
Why it mattersThe 2026 model guidance leaves generative and agentic AI to your own governance; the arithmetic itself is not a model under it.9
A strong answer"Vendor management and model risk have a path for AI tools, and every credit needs a named signer."
9
Vision · for reflection
If a borrower's controller asked tomorrow why last quarter's bill was $186,904.10, what would have to be true for you to answer with the clause, the rate and the arithmetic for every line within the hour?
Why it mattersYour answer lists the gaps: documents, rates, transactions, the calculation, the explanation. Each is a candidate job for software.
A strong answerA short list, for example: "every agreement indexed, fixings stored by date, one rounding rule, and each bill's calculation kept with it."
Explore, pilot or implement: what each score asks of your servicing team
0–6
Explore
Measure first: recalculate 50 recent bills by hand from their agreements, list your boarding defaults and conversion batches, and name an owner. Start narrow, with disputes or one conversion batch.
7–11
Ready to pilot
Recalculate one full quarter of your own bills in parallel with the live run, including bills you already know are wrong, and compare differences found, false alarms and minutes per dispute.
12–16
Ready to implement
Plan every run checked before the send: tolerance and hold rules, signing limits, the loan system and rate feeds, the dispute inbox, participant distributions, and audit access.
26 · Questions for any vendor
Testing loan interest calculation software on independence, day counts, SOFR lookbacks, fee bases and proof to the cent
In shortAsk every vendor the same questions, us included. The answers show whether the tool recalculates independently from the agreement or repeats your system's set-up, what it does when a rate or a term is missing, and what evidence a borrower, a participant or an examiner would see.
Ask
A good answer
A warning sign
Independence
Where do the terms come from: the signed agreement, or our system's set-up?
The agreement and every amendment, each term with its clause and page
"We import your loan set-up"
Is the system's billed amount ever an input to the recalculation?
Never; it is only compared at the end
Differences "adjusted" toward the system figure
How is a difference explained?
By replaying the system's set-up and reproducing the bill to the cent
A likely cause, unproven
Conventions
Which day counts, and which 30/360 month-end rules, does it support, per facility?
Actual/360, Actual/365, 30/360 variants as the agreement defines them, set per facility
One basis per borrower
Term SOFR, daily simple and compounded SOFR, lookbacks, observation shift, payment delay?
Each as the agreement words it, with the ARRC conventions as defaults3,4
"We use the SOFR rate"
How are floors applied on legacy loans with a spread adjustment?
To SOFR plus the adjustment, daily, as the clause says
To SOFR alone
What happens when a fixing is missing?
The calculation stops and says so, or applies the agreement's fallback
Interpolated or carried forward silently
Fees and charges
How is the unused fee base built?
By day, from the usage definition: loans, letters of credit, swingline, as the clause says
Period-end balance
How are default interest start and stop dates found?
From the notice, cure and waiver correspondence, against the notices clause
From the system's delinquency flag
Evidence and control
What does a borrower or an examiner see for one line?
The clause text, the fixing with its date, the arithmetic written out
A total and a status
Can it send a bill, a credit or a letter by itself?
No; drafts only, signed by a person, with limits and a second signature
"Auto-correct" switched on
How was its reading of agreements tested, and on whose documents?
On your own agreements, with known answers, measured per term
A single accuracy figure from someone else's set
Who changes our loan system's set-up when a cause is found?
Your loan operations, after supervisor approval; the tool proposes
The tool writes to the core system
27 · How to start
Test a recalculation tool on one quarter of your own bills, with known errors planted, before any bill is held
In shortMeasure first, then run the tool beside your live billing on a quarter you can check, with errors you know about, and decide on three numbers. Nothing is held or sent by the tool during the test; your current process stays in charge.
Recalculate 50 bills by hand from last quarter, half floating-rate with fees, and time each one. That is your baseline.
List what you already know: disputes and credits from the last year, conversion batches and their defaults.
Gather one quarter of bills, agreements, fixings and transactions for a few hundred loans, with approval to share them. Copy ten agreements and plant known differences.
Run in parallel for one billing cycle, with your analysts reviewing every difference the tool reports.
Decide with three numbers: differences found by cause, false alarms, and minutes from a dispute's arrival to a signed answer.
A ten-week test ends with a decision on three numbers
Your teamVendor
Baseline: 50 bills by hand
Agreements, fixings and extracts
Terms read and confirmed
Planted differences checked
Parallel billing cycle
Measure and decide
Week 03610
Illustrative · replace with your own numbers
Show the numbers
Activity
From
To
Baseline: 50 bills by hand
0
2
Agreements, fixings and extracts
1
3
Terms read and confirmed
2
5
Planted differences checked
4
6
Parallel billing cycle
5
9
Measure and decide
9
10
Five numbers to record during the parallel billing cycle
Measure
How
Why
Differences found, by cause
Real and planted differences found ÷ present, per cause
One percentage hides a missed day-count batch
False alarms
Bills held that were right, and the minutes to clear each
A tool that holds everything finds everything
Terms read correctly
Every term on 30 agreements checked against the documents
The arithmetic is only as good as the terms
Minutes per dispute
From arrival to a signed answer, with and without the tool
The cost case rests on it
Underbills found
Dollars in the bank's disfavor, by loan
Nobody else will report them
The full working-session questions: 18 questions in six groups
Bring loan servicing, billing, agency services, loan operations, loan accounting, model risk, vendor management and IT into one room. Answer these before you talk to any vendor.
A
Scope: bills, roles and send times
A1
How many bills a year, by product: fixed, Term SOFR, daily SOFR, prime, with revolvers and letters of credit?
Why it mattersThe errors gather in floating rates, lines and fees.
Strong answer · warning sign
Counts by product.
One total.
A2
Which loans are agented by us, and which do we hold as a participant?
Why it mattersAs agent you calculate; as participant you check the notices.
Strong answer · warning sign
A list with roles.
Unknown.
A3
When do bills go out, and how much time is there to hold and fix one?
Why it mattersSets when the check must run.
Strong answer · warning sign
A schedule with send times.
"Whenever the batch runs."
B
Documents: agreements, notices and certificates
B1
Where are the agreements, amendments, fee letters, certificates, notices and waivers?
Why it mattersEvery term has to come from a document.
Strong answer · warning sign
One indexed repository.
Shared drives and inboxes.
B2
Who records notices of default and waivers, and where?
Why it mattersThey set default interest dates.
Strong answer · warning sign
Logged with delivery evidence.
In someone's email.
B3
How are compliance certificates fed to the pricing grid?
Why it mattersA missed step-down repeats every period.
Strong answer · warning sign
A named hand-off with a date.
"Credit admin tells ops."
C
Rates: tenors, calendars and legacy LIBOR loans
C1
Which Term SOFR tenors and which prime rate do we license, and where are fixings stored by date?
Why it mattersThe check needs the same published values.
Strong answer · warning sign
A dated history.
Only today's rate.
C2
Which calendar does each loan's fixing use?
Why it mattersBond-market days differ from banking days.4
Strong answer · warning sign
Stored per loan.
One bank calendar for all.
C3
Which legacy LIBOR loans fell back, and on what terms?
Why it mattersSpread adjustments and floors work differently on them.6
Strong answer · warning sign
A list with the fallback clause.
"They're all SOFR now."
D
Set-up: boarding defaults and conversion batches
D1
What defaults does our loan system apply at boarding: day count, grace, rounding?
Why it mattersEvery default that differs from an agreement is a repeating error.
Strong answer · warning sign
A written list.
Nobody knows.
D2
Which loans were boarded in batches, and were they checked?
Why it mattersOne cause, many loans.
Strong answer · warning sign
Batches with sample checks.
No record.
D3
Who approves a set-up change, and who applies it?
Why it mattersMaker and checker on the system of record.
Strong answer · warning sign
Supervisor approves, operations applies.
Whoever finds it.
E
Governance: SR 26-2, signing limits and vendor review
E1
Has our model risk policy moved from SR 11-7 to SR 26-2, and where do AI tools fit?
Why it mattersThe old letter was replaced on April 17, 2026.9
Strong answer · warning sign
Updated, with an AI path.
Still cites SR 11-7.
E2
What are our signing limits for credits and rebills?
Why it mattersThey become settings.
Strong answer · warning sign
Written, by role.
"It depends."
E3
What does vendor management need before a test sees real loan data?
Why it mattersSets the start date.
Strong answer · warning sign
A known path.
First time anyone has asked.
F
Vision: holding bills and showing participants the arithmetic
F1
What if no bill left the building without matching its agreement?
Why it mattersTests the appetite for holding bills.
Strong answer · warning sign
"Then disputes become rare."
"We can't hold a bill."
F2
What if every participant could see the arithmetic behind its share?
Why it mattersLinks billing to agency work.
Strong answer · warning sign
Fewer claims.
"They don't need to know."
F3
Which steps would we never let software do without a person?
Why it mattersTells you where the signatures belong.
Strong answer · warning sign
Credits, letters, releases, set-up changes.
"All of it": then start with recalculation only.
28 · Frequently asked questions
Answers on 365/360 legality, Term SOFR arithmetic, unused line fees, default interest and SR 26-2
In shortThe questions servicers, borrowers and buyers search for most, each answered on its own.
How is interest calculated on a commercial loan?
Interest for each period equals the outstanding balance times the annual rate times the number of days, divided by the days in the year the agreement uses. The period is split wherever the balance or the rate changes, each slice is calculated separately, and the slices are added and rounded as the agreement says.
What is the 365/360 method of calculating interest?
The 365/360 method divides the annual rate by 360 to get a daily rate and charges it for every actual day the money is out. Over a normal year the borrower pays 365/360 of the stated rate, about 1.39% more interest. It is the same arithmetic as Actual/360, the usual convention for commercial and SOFR loans.
Is 365/360 interest legal?
Courts have generally enforced it where the note states it. The Eighth Circuit in 2011 and the Ohio Supreme Court in 2012 rejected borrowers' claims that a stated annual or "per annum" rate required a 365-day year, because the notes spelled out the method. The outcome depends on the note's exact wording and the governing state's law.
What is the difference between Actual/360 and 30/360?
Actual/360 counts the real number of days in a period over a 360-day year, so a 31-day month costs 31 days. 30/360 counts every month as 30 days, so July costs the same as September and a year costs exactly the stated rate. Agreements often use 30/360 for amortizing term loans and Actual/360 for revolvers and fees.
How is Term SOFR interest calculated?
Take the Term SOFR rate published two U.S. Government Securities Business Days before the interest period, apply any floor, add any spread adjustment and the margin, and charge that rate on the balance for the actual days of the period over 360. The rate is held for the whole period; it changes only at the next period.
What is the difference between daily simple SOFR and compounded SOFR?
Daily simple SOFR charges each day's SOFR on that day's principal and adds the results; compounded SOFR also charges interest on the interest built up earlier in the period. Both are known only after the period, so agreements use a lookback. The ARRC says the difference is usually a few basis points or less.
What is a SOFR lookback with an observation shift?
A lookback takes each day's rate from a few business days earlier so the bill can be ready on time. An observation shift also moves the day weights to the earlier calendar. The ARRC recommends a lookback without an observation shift for syndicated loans, because a shift can over- or undercharge a loan prepaid mid-period.
How does an interest rate floor work on a SOFR loan?
If the benchmark falls below the floor, the floor is used instead. For new loans the ARRC recommends applying the floor to Term SOFR itself; for legacy LIBOR loans that fell back to SOFR it applies to SOFR plus the spread adjustment. For SOFR in arrears, the floor is tested daily.
How is an unused line fee calculated?
Work out the unused commitment each day, usually the commitment less loans and letters of credit, multiply by the fee rate, and charge it for the actual days over 360, splitting the period wherever usage changes. The base is where disputes start: the agreement's definition of usage decides whether letters of credit and swingline count.
How is default interest calculated on a commercial loan?
Default interest is the balance times the extra default margin, often 2% a year, times the days the default rate applies, over the agreement's year. The days run from the date the agreement says, on default, on notice or at the lender's election, until the default is cured or waived.
Can a late fee or default interest be unenforceable?
Yes, in some states. California courts treat a charge measured on the whole unpaid balance for a missed installment as a penalty, as in Garrett (1973) and Honchariw (2022), which struck 9.99% default interest on a $5.6 million commercial loan. New York removes rate limits on loans of $2.5 million or more.
Is loan interest calculation software a model under SR 26-2?
The arithmetic is not. SR 26-2, issued April 17, 2026, excludes simple arithmetic calculations and deterministic rule-based processes from its definition of a model. Generative and agentic AI used to read agreements is outside its scope and falls under the bank's own governance, with evidence and human sign-off.
29 · One-page summary
A loan bill check on one page: six steps, the rule dates from LIBOR's end to SR 26-2, and a glossary of day-count and SOFR terms
Print this page
In shortThe whole guide on one screen: how to check a bill, the rules as of October 2026, the readiness bands and fourteen terms.
Checking a bill
Read every pricing and fee term from the agreement and its amendments, with the clause.
Work out each fixing date from the clause and take the published rate; test the floor.
Split the period at every draw, repayment, reset, margin step and default change.
Count days under each facility's day count; round as the agreement or your rule says.
Compare line by line with the system; prove the cause by reproducing the system's figure.
Hold, correct, sign; co-sign above the limit; fix the set-up for every loan boarded the same way.
Readiness: score 0–2 on eight questions: 0–6 explore · 7–11 pilot · 12–16 implement.
As of October 2026: LIBOR ended September 30, 2024 · Regulation ZZ spread adjustments 0.11448% / 0.26161% / 0.42826% / 0.71513% (one-, three-, six-, twelve-month LIBOR) · SR 26-2 replaced SR 11-7 on April 17, 2026 · prime 7.00% from September 17, 2026.
14 terms
Day count
The rule for counting a period's days and a year's length.
Actual/360 (365/360)
Real days over a 360-day year; costs 365/360 of the rate a year.
30/360
Every month counted as 30 days over a 360-day year.
Accrual period
A slice of a bill with one balance and one rate.
Term SOFR
A forward-looking SOFR rate, read before the period and held for it.
Daily simple SOFR
Each day's overnight SOFR on that day's principal, added up.
Lookback
Taking each day's rate from a few business days earlier.
Fixing
A benchmark's published value on the day the agreement names.
Floor
A minimum for the benchmark rate.
Spread adjustment
A fixed amount added to SOFR in place of LIBOR's higher level.
Margin
The lender's spread over the benchmark, sometimes on a pricing grid.
Unused line fee
A yearly percentage on the undrawn commitment.
Default rate
The higher rate while a default continues, often +2%.
USGS business day
A U.S. Government Securities Business Day: the bond market's calendar.
30 · Sources
Sources
Accessed October 2026. Regulatory status statements are as of October 2026.
Kreisler & Kreisler, LLC v. National City Bank, No. 11-1772 (8th Cir. October 6, 2011). ecf.ca8.uscourts.gov
Orrick InfoBytes, "Ohio Supreme Court upholds dismissal of class action challenging bank's interest calculation method" (JNT Properties, LLC v. KeyBank N.A., 2012-Ohio-5369, decided November 21, 2012), December 3, 2012. infobytes.orrick.com
Alternative Reference Rates Committee (ARRC), "SOFR 'In Arrears' Conventions for Syndicated Business Loans", July 22, 2020. newyorkfed.org
ARRC, "Forward Looking Term SOFR and SOFR Averages (Applied in Advance) Conventions for Syndicated and Bilateral Business Loans", July 2021. newyorkfed.org
12 CFR 1026.3(a), Regulation Z exempt transactions: business, commercial, agricultural or organizational credit (2026 edition). govinfo.gov
Board of Governors of the Federal Reserve System, "Regulations Implementing the Adjustable Interest Rate (LIBOR) Act" (Regulation ZZ), final rule, 88 FR 5204, January 26, 2023, effective February 27, 2023. govinfo.gov
Buchalter, "Caution to Lenders: New Pitfalls to Imposing Default Interest and Late Fees on Defaulted Loans" (Honchariw v. FJM Private Mortgage Fund, LLC, California Court of Appeal, September 29, 2022), March 28, 2023. buchalter.com
Federal Reserve, SR 26-2, "Revised Guidance on Model Risk Management" (joint with OCC Bulletin 2026-13 and FDIC FIL-15-2026), April 17, 2026, and attachment. federalreserve.gov
FRED, Bank Prime Loan Rate (DPRIME), read October 31, 2026. fred.stlouisfed.org
12 CFR 7.4001, charging interest by national banks (2026 edition). govinfo.gov
New York General Obligations Law § 5-501, subdivision 6. nysenate.gov
Garrett v. Coast & Southern Federal Savings & Loan Assn., 9 Cal.3d 731 (Supreme Court of California, July 18, 1973). scocal.stanford.edu
Vorys, "365/360 Interest Calculation: Latest Developments in Ohio Case Law Provide Guidance in Interest Calculation Methods", The Bankers' Statement, Winter 2014. vorys.com
Federal Reserve Bank of St. Louis, FRED, Secured Overnight Financing Rate (SOFR), daily and quarterly averages, read October 31, 2026. fred.stlouisfed.org
LexisNexis Practical Guidance, "Determining Spread Adjustments for SOFR Loans", March 7, 2022. lexisnexis.com
LexisNexis Practical Guidance, "Trends in SOFR Spread Adjustments and Rate Floors", October 18, 2022 (100 credit agreements reviewed since May 2022). lexisnexis.com
Law Insider, "Unused Commitment Fee" sample clauses from filed agreements, accessed October 31, 2026. lawinsider.com
Law Insider, "Letter of Credit Fees" sample clauses from filed agreements, accessed October 31, 2026. lawinsider.com
Law Insider, "Fronting Fee Rate" definitions from filed agreements, accessed October 31, 2026. lawinsider.com
Federal Reserve, FDIC and OCC, "Shared National Credit Program: 2025 SNC Program Charts", January 12, 2026. fdic.gov
Reuters, "Citigroup wins appeal over mistaken Revlon wire transfer", September 8, 2022 (via Investing.com). investing.com
J. Hill, "2nd Circ. Gives Citi Win In $500M Revlon Wire Transfer Fight", Law360, September 8, 2022 (copy posted by Mayer Brown). mayerbrown.com
M. Carolan, "IBRC liquidators get court approval for repayment process", The Irish Times, November 28, 2016. irishtimes.com
Consumer Financial Protection Bureau, "CFPB Orders Wells Fargo to Pay $3.7 Billion for Widespread Mismanagement of Auto Loans, Mortgages, and Deposit Accounts", December 20, 2022. consumerfinance.gov
"Carleton survey shows depth of loan calculation errors, compliance strains & resource burdens", Auto Remarketing, September 4, 2025. autoremarketing.com
S. Wolak, "Mortgage lenders struggle with compliance, loan calculation accuracy: survey" (Carleton survey), HousingWire, September 23, 2025. housingwire.com
FRED, Commercial and Industrial Loans, All Commercial Banks (BUSLOANS), H.8, read October 31, 2026. fred.stlouisfed.org
Federal Reserve, press release on the 2025 Shared National Credit Program report, January 12, 2026. federalreserve.gov
O*NET OnLine, Loan Interviewers and Clerks (43-4131.00), Bureau of Labor Statistics 2025 wage data. onetonline.org
O*NET OnLine, Loan Officers (13-2072.00), Bureau of Labor Statistics 2025 wage data. onetonline.org
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