We want to send a letter to selected customers offering to defer their December payment. The loans will be simple interest consumer loans that are either unsecured or secured by vehicles, or other consumer goods. The customer will sign the letter which authorizes the deferral, and return it along with a deferral fee.
Does anyone see any problems with this offer?

You will want to check state law. Some states have laws on the books prohibiting or limiting the amount of deferral fees.

Review the criteria developed for determining who will receive the deferral offer. Do your criteria create any fair lending issues?

Also, there is some existing interaency guidance on consumer credit that limits the number of time you can re-age an account(that is the effect of deferring a payment).