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Can a Licensee defer the presentment of a check beyond 31 days during the state of emergency posed by COVID-19?
Yes. A licensee may extend the maturity date of a transaction due to the impact of COVID-19 if the following requirements are met:
- The licensee obtains voluntarily written or verbal notification from the customer, which is verifiable in writing or by electronic means, that the customer:
- Desires to extend the transaction beyond 31 days and
- Understands that by keeping this transaction open, their eligibility to obtain additional deferred transactions will be impacted and they may not be eligible to obtain a new transaction until the current transaction is paid; and,
- The licensee does not assess, charge, or collect any additional fee from the customer in exchange for extending the transaction beyond 31 days.
A licensee that assesses, charges, or collects any additional fee from a customer in exchange for extending the transaction beyond 31 days may be subject to administrative discipline under the Deferred Presentment Service Transactions Act (DPSTA).1
1 The Veritec database will not allow a licensee to enter a maturity date that is more than 31 days from the transaction date. When extending transactions beyond 31 days, licensees must place an auto-close hold on the transaction and document the new maturity date within their own system or customer records. Please note an auto-close hold cannot be entered prior to the maturity date. Management should generate reports in Veritec of open transactions by due date to identify when auto-close holds can be applied to specific transactions. Licensees must ensure transactions remain open in the Veritec database until the obligations are satisfied. Written notification from the customer may be obtained by email, text or fax. When verbal notification from the customer is obtained, it is highly recommended the licensee record the call. If this is not possible, the licensee must document the verbal request either in the licensee system or the customer file. A single transaction may be extended multiple times as long as the final maturity date does not extend past June 1, 2020 and no additional fees are charged.