OCCC and Finance Commission Report Information, Meeting is Friday 10/20 and will summarize data from September 0f 2016 to August of 2017.

CAB Examinations:  Down from 707 in 2016 to 652 in 2017 (-7%).

CAB acceptable level of compliance: 98.93%.

Complaints processed payday: 208 in 2016 and 148 in 2017 (-28.8%).

Complaints processed title: 198 in 2016 and 147 in 2017 (-25.7%).

Top 3 Complaint Types Payday:

Overcharges:8.8.

Financial hardship:14.9.

Payment processing: 25.7.

Top 3 Complaint Types Title:

Financial hardship: 13.6.

Repo: 14.3.

Payment Processing: 21.8.

Jan-June 2017 and other years during same period,  CAB Reporting said:

Unsecured installment and payday loans have been almost exactly flat in the last (4) years going back to 2014, hovering in the 1.044 to 1.1 million loans range for the Jan-June periods.

For comparison, the highest year was 2013 with 1.2 million loans and 3,176 locations reporting activity.  In 2017 the locations totals are 1,817 – this is a new number I have been seeing 2,200-ish.

(ATTENTION CITIES AND CONSUMER ADVOCATES WHO PASSED CITY ORDINANCES TO PASS – ARE YOU READING THIS???) 

Title loans in the last (2) years are hovering flat in the 129,000-133,000 range, with a steady drop from 2013 when there were 241,000 in the same six-month period.

Repos – steady in the 15,000 range the last (2) years.

# Consumers using products Jan-June of 2017, 2016, 2015:

Single payment payday loans in 409k, 453k, 510k

Unsecured installment loans:416k, 385k, 365k

Single payment title loans: 63k, 71k, 109k

Installment title loans: 53k, 53k, 36k

This blog post was written by Michael Brown, President of CAB Consulting and the Texas Organization of Financial Service Centers.  He can be reached at 214-293-8676, or Michael@CreditAccessBusiness.com.

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CFPB issued the final Payday Loan Rule today

by The CAB Man Texas on October 5, 2017

CFPB Rule came out today.  It is 1,600+ pages and I am hearing from folks on it but no one knows a lot at this point.  I need to start reading and as I connect with others to learn more I will of course relay what people are saying.

Effective date is 21 months after date of publication in the Federal Register. I do not know when it was or when it will be in the Federal Register.  As far as who it covers and what kinds of loans it applies to, I need to look.

Here is the link:

https://s3.amazonaws.com/files.consumerfinance.gov/f/documents/201710_cfpb_final-rule_payday-loans-rule.pdf

This blog post was written by Michael Brown, President of CAB Consulting and the Texas Organization of Financial Service Centers.  He can be reached at 214-293-8676, or Michael@CreditAccessBusiness.com.

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Credit Access Businesses offering payday, installment, and title loans help US consumers avoid padding the banks fat pockets

October 3, 2017

So much time and effort is spent on attacking the “payday loan industry” it is baffling.  Why do consumer advocates and the CFPB refuse to make the banking industry Public Enemy #1 instead? See below for a shocking breakdown of how banks target and abuse US Consumers with un-godly annual revenue via Overdraft and NSF […]

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Texas OCCC issues advisory bulletin to licensees on how to remain in compliance while dealing with Harvey aftermath

September 8, 2017

Our friend ROb Norcross at CSAT sent over some really good details that he had gathered in response to the OCCC issuing advisory bulletins to licensees on how to remain in compliance while dealing with Harvey aftermath.  I scraped some of those details and organized them below for CAB stakeholders in Texas, and business owners […]

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The infamous and continuously failing Texas Payday Loan City Ordinance.

August 22, 2017

Since Texas cities began passing the infamous and continuously failing Texas Payday Loan City Ordinance there has been a decrease of 1,300 or so licensed locations inside the State.  According to the most recent OCCC licensee totals, this represents a 37% market shrink.  The results have been a shuttering of businesses in Texas, a loss […]

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The OCCC is seriously focused on Credit Access Business Examinations right now – are you ready?

August 21, 2017

Over the last several weeks there has been a significant uptick in OCCC examinations of our Credit Access Business friends and clients.  Are you ready for the OCCC to walk in your door?  Chances are if you are a member of TOFSC or if you are a client of of CAB Consulting you are in […]

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OCCC Compliance Basics from CAB Consulting

June 27, 2017

Just a reminder for all of you CABs out there – continually review your Consumer Transaction Information Disclosures & Fee Schedules. Many times throughout the course of the year CAB operators may change their CAB fee amounts or offer different loan products such as offering multi-payment installment loans, payday loans, or auto title loans.  When […]

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The Houston Chronicle is dabbling in the in Payday and Title Loan conversation again

June 20, 2017

Babin, DiNardo: State should not loosen payday lender regulations. Written by Anna M. Babin and Cardinal Daniel DiNardo.  Let’s take a minute and dice up this Houston Chronicle piece on Texas Credit Access Businesses.  The newspaper was apparently not satisfied with their role in passing the Houston “Payday Loan Ordinance” which caused a massive amount of […]

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CFPB released a new kind of complaints report

June 19, 2017

After not being able to find the CFPB monthly complaint report on payday loans last week, I found it Wednesday which was a bit later than normal.  The delay might have been because it is a different kind of report, it is focused on “older” complainants who were 62+ years of age. This new format […]

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Payday Boot Camps offered by CAB Consulting at Partner store location in Austin, Texas

June 15, 2017

CAB Consulting has partnered with Star of Texas Financial Solutions in the Austin, Texas area to offer live in-store training sessions to start ups wanting wide and narrow scope guidance on how to get going with their payday, installment, or auto title loan venture.  As well, Payday Boot Camps are often conducted for existing companies […]

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