Why The EPP Isn’t Offered In Kentucky

I wanted to share an email I received from the CFSA. I sent an email to the CFSA (MAllieCFSA@multistate.com) and asked them why Kentucky store front lenders do not offer an extended payment plan to their customers, the response I received was….well…. you interpret it and get back with me!

Me:

Please show me the state regulation that says Kentucky payday lenders are exempt from offering an extended payment plan as outlined according to your guidelines.

CFSA response:

Good Morning,

Thank you for your email to CFSA.  In order to ensure that we provide you with an accurate and complete response to your question, can you please advise as to whether you are a member of CFSA or a customer of a CFSA member? If so, please let us know your specific issue and we may be better able to help.  As general information, CFSA member companies do agree to comply with the CFSA Best Practices, which includes a best practice concerning extended payment plans.  Our best practices are contained on our website at www.cfsa.net. If you need further information or can be more specific as to the issue that you are encountering, please let me know and we will do our best to be of further assistance.

Me:

I am writing to you on behalf of a customer, who currently has a payday loan with a payday lender who is a member of the CFSA. The customer requested an EPP but was refused, the reason this customer was given was ” Kentucky state regulations exempted them from providing an EPP”. I would like to read that specific regulation that exempts KY from extending extended payment plans as required by the CFSA.
Thank you.

CFSA Response:

Thank you for the additional details. I followed up on Kentucky specifically for you.  It is my understanding that the reason CFSA Payment Plans are not offered in Kentucky is the limitation in state law on how long a deferred deposit transaction can be held. I believe the section of the Kentucky Statutes that sets that limit is Section 286.9-100(12).  I hope that is helpful and addresses your question. Thank you for contacting CFSA.

Best Regards,

Monica Allie
CFSA Consultant

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