THC Financial Corp. v. Managed Investment Corp.

643 P.2d 549, 64 Haw. 491, 1982 Haw. LEXIS 162
CourtHawaii Supreme Court
DecidedApril 15, 1982
DocketNO. 7214
StatusPublished
Cited by2 cases

This text of 643 P.2d 549 (THC Financial Corp. v. Managed Investment Corp.) is published on Counsel Stack Legal Research, covering Hawaii Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
THC Financial Corp. v. Managed Investment Corp., 643 P.2d 549, 64 Haw. 491, 1982 Haw. LEXIS 162 (haw 1982).

Opinion

OPINION OF THE COURT BY

LUM, J.

In this case, we need to determine whether the usury laws of Hawaii were violated in regard to three loan agreements between plaintiff-appellee THC Financial Corporation and defendants-appellants Managed Investment Corporation, Durrel L. Robison and Jeanne B. Robison.

Plaintiff filed a complaint in the circuit court for collection of principal and interest due on these promissory notes 1 and for the *492 foreclosure of the real estate securing these notes. The court later found the notes to be in default, and entered its findings of fact and conclusions of law in which the court determined the amounts owed by the defendants and decreed that the property be sold.

The trial court’s findings left no doubt that the 365/360 method 2 was used to calculate the amount of interest the principal amounts accrued each day. 3 The court found that the amount of interest owed was $61,116.21 and that the principal sums continued to accrue interest in the aggregate sum of $60.00 per day. After the mortgaged property was sold, a dispute arose concerning the interest amount legally owing.

*493 Defendants denied liability for interest, relying on HRS § 408-16, and counterclaimed for refund on account of usurious interest. Plaintiff filed a motion for summary judgment. The motion was granted and the counterclaim dismissed. Judgment was entered in favor of plaintiff in the sum of $85,950.73; the amount representing interest due was within the maximum annual interest rate. Defendants brought this appeal. We affirm.

Defendants contend that plaintiff exceeded the interest limitations of HRS § 408-15 4 (1976 & Supp. 1981) when it computed interest by means of the 365/360 method. Since plaintiffs use of the 365/360 method results in an annual interest charge of 18.25 percent and the 365/365 and 360/360 methods would result in an annual interest charge of 18.0 percent, 5 defendants assert that the sanction of HRS § 408-16 6 (1976) applies.

*494 The 365/360 method of computing interest has been a standard method of the banking industry for the past two centuries. The majority of early cases refused to hold that interest resulting from the use of the 365/360 method at the maximum legal rates is usurious. These cases held that computational convenience and banking custom justified the use of the 365/360 method. See cases cited in Comment, supra at 145-50. But interest is now calculated by computers, and the rationale of the earlier cases is no longer persuasive to all courts. In American Timber & Trading Co. v. First National Bank of Oregon, 511 F.2d 980 (9th Cir. 1974), cert. denied, 421 U.S. 921 (1975), the United States Court of Appeals for the Ninth Circuit, applying Oregon law, found that the bank’s use of the 365/360 method of computation was usurious and agreed with the district judge’s determination that the usury statute “should be construed with regard to its net effect upon the borrower rather than upon the bookkeeping burden, custom, or convenience of the lender.” Id. at 983. American Timber has been followed by most courts who have subsequently considered this issue. See Cagle v. Boyle Mortgage Company, 261 Ark. 437, 549 S.W.2d 474 (1977); Ellis National Bank of Tallahassee v. Davis, 359 So.2d 466, 468-69 (Fla. App. 1978); cert. denied, 365 So.2d 711 (Fla. 1978), cert. denied, 440 U.S. 976 (1978); Cochran v. American Savings & Loan Ass’n, 568 S.W.2d 672 (Tex. Civ. App. 1978), modified 586 S.W.2d 849 (1979); O’Brien v. Shearson Hayden Stone, Inc., 90 Wash.2d 680, 586 P.2d 830, 836 (1978). But see Martin v. Moore, 269 Ark. 375, 601 S.W.2d 838, 839 (1980); Beazley v. Georgia Railroad Bank & Trust Co., 144 Ga. App. 215, 241 S.E.2d 39, 40 (1977).

Although we agree with the reasoning of American Timber and its progeny, we do not find it dispositive of the instant case. We must determine whether, in light of American Timber’s reasoning, the sanc *495 tion provided by HRS § 408-16 is available to defendants.

HRS § 408-15(j) permits an industrial loan company to “contract for and receive” interest at a rate not exceeding one and one-half percent per month on the unpaid balance of a loan.

HRS Chapter 408 provides two sanctions where an industrial loan company violates the limitations on interest rates set by HRS § 408-15. One sanction is established by HRS § 408-29 (1976) which mandates a fine for any willful and knowing violation of any provision of the chapter. The other sanction is contained in HRS § 408-16 which provides:

[I]f, in any action on the contract, proof is made that a greater rate of interest than that permitted by this chapter has been directly or indirectly contracted for, the plaintiff shall only recover upon the contract the amount actually received by the borrower on the contract....

The legislature has defined usury in different ways, arid these definitions indicate the legislature’s intent to draw distinctions between “charging” excessive interest, “receiving” excessive interest, and “contracting for” excessive interest. 7 Since HRS § 408-16

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Bluebook (online)
643 P.2d 549, 64 Haw. 491, 1982 Haw. LEXIS 162, Counsel Stack Legal Research, https://law.counselstack.com/opinion/thc-financial-corp-v-managed-investment-corp-haw-1982.