As a member of the Community Financial Services Association of America (CFSA), we encourage responsible industry practices that offer appropriate consumer protections. We support and abide by CFSA's Best Practices as outlined below. We value your trust in us and we appreciate having the opportunity to serve you.

1. Full disclosure. A member will comply with all applicable state or federal disclosure requirements. In the absence of specific state regulation, a member must fully disclose to the customer all details of the payday advance transaction. A contract between a member and the customer must fully outline the terms of the payday advance transaction. Members agree to disclose the cost of the service fee both as a dollar amount and as an annual percentage rate (APR).

2. Compliance. A member will not charge a fee for the payday advance service, nor engage in any practice designed to charge a fee, that exceeds that authorized by applicable law. A member will not charge additional add-on fees, such as a late fee, not authorized by state or federal law.

3. Truthful advertising. A member will not advertise the payday advance service in any false, misleading, or deceptive manner. CFSA supports as a guideline for truthful advertising the advertising regulations contained in the Federal Truth-in-Lending Act.

4. Encourage consumer responsibility. A member will implement policies and procedures to inform consumers of the intended use of the payday advance service. These policies will include notifying consumers that a payday advance is a short-term cash flow tool, not designed as a solution for longer term financial problems.

5. Limit/prohibit rollovers. Although a payday advance is a short-term solution to an immediate need, we recognize that a short-term cash flow problem may take several pay periods in order to correct itself. In states where rollovers are prohibited by applicable law, a member will not, under any circumstances, allow a customer to do rollovers. In states where rollovers are permissible, a member will follow applicable state law but in no case allow a customer to rollover a transaction more than four times.

6. Right to rescind. A member will give its customers the right to rescind, at no cost, a payday advance transaction on or before the close of the following business day.

7. Appropriate collection practices. A member must collect past due accounts in a professional, fair and lawful manner. A member will not use unlawful threats, intimidation, or harassment to collect accounts. CFSA believes that the collection limitations contained in the Fair Debt Collection Practices Act (FDCPA) should guide a member's practice in this area.

8. No criminal action. A member will not threaten or pursue criminal action against a customer as a result of the customer's check being returned unpaid or the customer's account not being paid.

9. Self-policing of the industry. A member will participate in self-policing of the industry. A member will be expected to report violations of applicable law to CFSA, which will in turn bring the matter to the attention of the violator. If the violation does not cease, the violator will be reported to the state
   regulatory authority. Each member company agrees to maintain and post its own toll-free consumer hotline number in each of its outlets.

10. Support balanced legislation. A member will work with state legislators and regulators to support responsible legislation of the payday advance industry that incorporates these best practices.

11. Relationships with financial institutions. A member may market and service payday advances made by federally insured financial institutions only if certain criteria are met.