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#2257418 - 07/29/21 09:49 PM Payment Extension - Consumer Installment Loan
TeamComply Offline
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Joined: Aug 2016
Posts: 393
Curious how other FIs handle payment extensions on consumer installment loans. Do you require that a flat payment amount be made or that a portion of a payment be made, or that interest be paid? What do you require as far as a payment goes in order to grant an extension? Or do you make a payment extension without requiring anything to be paid by the borrower?

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#2257458 - 07/30/21 05:44 PM Re: Payment Extension - Consumer Installment Loan TeamComply
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 46,371
Bloomington, IN
State law dictates what you can or cannot charge for payment deferrals and what disclosures (if any) must be provided.

You should start there to see what your options are.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#2257478 - 07/30/21 08:11 PM Re: Payment Extension - Consumer Installment Loan Dan Persfull
TeamComply Offline
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Joined: Aug 2016
Posts: 393
Thank you, appreciate the info.

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#2257480 - 07/30/21 09:35 PM Re: Payment Extension - Consumer Installment Loan TeamComply
Richard Insley Online
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Richard Insley
Joined: Oct 2000
Posts: 9,987
Toano, VA
If you are starting to offer extensions for the first time, you should look at any safety & soundness guidance or enforcement policies from your regulator. Since liberal extensions are an easy way to hide non-performing assets, your regulator will most likely look at your procedures.
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