March 25, 2020

AILA Members and Friends:

The Alabama State Banking Department has determined that licensees are performing Essential Services as described in the attached Memorandum from the Secretary of the Treasury. For those choosing to rely upon it to remain open for business, please be mindful of various Health Department Orders and Municipal Ordinances that have been adopted throughout the Cities, Counties and the State.

In response to my request the State Banking Department has offered guidance with respect to handling deferral of payments under the Small Loan Act Alternative Rate structure of Section 5-18-15(m):

Mr. Shevin,

In response to your recent question, please be advised that the Department offers the following guidance. In working with customers during these uncertain times, Small Loan Act licensees offering loans under the Alternative Rate may, but are not required, to charge up to a maximum of $18 to defer a payment 10 days or more if late or deferral charges are provided in their loan contract. Deferral fees under the SLA are treated the same as Late fees under Section 5-18-15(e). Therefore, only one deferral fee may be assessed per deferred installment.

Scott Corscadden

Supervisor, Bureau of Loans

Alabama Banking Department

401 Adams Avenue, Suite 680

Montgomery, AL 36104

I hope that you and your family remain healthy. Maury

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