Notices and Disclosures for use in Credit Access Business Operations

by The CAB Man Texas on December 20, 2011

In addition to the provisional license, last Friday the OCCC worked to get rules for the Notices and Disclosures approved.  The rules, referred to as “7 TAC 83.6001-7 TAC 83.6008,” define the many ways in which a Credit Access Business is required to disclose particular information to consumers regarding the potential loan they are about to apply for, or for the actual loan that consumers agree to.

There are procedural requirements that a Credit Access Business address the nature of the transaction and possible alternatives to this service before the customer completes an application.   Also, the customer must acknowledge they have received these disclosures.

Considerable time has been invested in the development of several documents the OCCC advises Credit Access Businesses to use that are compliant with the law, and accomplish the goals of House Bill 2592.  Focus groups have reviewed the documents, and feedback was provided that shaped the final versions.  In the future it is likely that continued feedback from focus groups will shape these “dynamic” documents in a way that makes sense to all Credit Access Business consumers and stakeholders.

According to the OCCC, there is only one other state in the U.S. that has something similar or nearly as comprehensive.  The process of collaboration between the OCCC and industry stakeholders appears to have resulted in an exceptional set of detailed disclosures, which should please lawmakers and consumer advocate groups.   Fair regulations were passed, and rules were developed to implement the new State of Texas laws.  This high level State government achievement in should be made note of at the local level.  Knowing that such thorough systems are in place, city governments can now move on to more important topics like job creation and budget balancing.

The documents, which focus on single and multi-payment payday and title loans, are available through the OCCC website.  CAB Consulting and Brokerage is also in possession of the documents.  We are distributing them to clients, building familiarity with their intent, and drawing clarity from a 15 page two column set of rules.

If you have questions or would like to discuss, please contact CAB Consulting and Brokerage at 214-293-8676, or via email at cabconbrokerage@gmail.com

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