The Payoff Desk Is a Compliance Surface: Quoting Payoffs, Reinstatements, and Partial Payments With an AI Agent Under Regulation Z 1026.36(c)
A payoff quote looks like a lookup and is actually a per-diem calculation with a statutory delivery clock, a good-through date the borrower relies on, and a payment-application rulebook underneath it. Where servicers get the numbers wrong, why suspense accounts and late-fee pyramiding turn cashiering into a Regulation Z problem, and what an AI agent on the payoff desk is allowed to compute versus what stays with the servicer.