Website Design to Ensure Compliance with the O.C.C.C.

Website Design to Ensure Compliance with the O.C.C.C.

by The CAB Man Texas on April 3, 2012

C.A.B. Consulting and Brokerage works with Texas Credit Access Businesses on their licensing, compliance, operations, and third party lender needs. Recently they partnered with Orangebook Website Design to offer Texas CAB’s dynamic websites at a discounted price.

Per its Rules for Credit Access Businesses, the O.C.C.C. asks that certain documentation (Consumer Disclosures, Licenses, Fee Schedules, and Notices) not only be displayed in-store but also on websites through which Texas CABs advertise their services. Orangebook Website Design has been educated on the regulations and will redesign or build a new website for your business that ensures compliance in the internet marketplace.

Orangebook Website Design is offering Texas CABs a greatly reduced price for a new website build. Orangebook Website Design has reduced the list price for a 5 Page website from $975 to $745 for C.A.B. Consulting and Brokerage referrals.

5 Page Features ($745)

  • Complete Custom Web Design (No Templates)
  • Home Page Flash Intro
  • Unlimited Design Revisions
  • Contact Page with Contact Form
  • Search Engine Friendly Web Site
  • Social Media Links to Facebook, Twitter, and MySpace
  • Dedicated Contact Personnel for Your Project
  • Free Online Payment Interface
  • You Own Your Web Design – Onetime Cost for Web Design

An 8 Page website originally priced at $1,540 is now reduced to $1,185 for C.A.B. Consulting and Brokerage customers.

8 Page Features ($1,185)

  • All Features Listed for the 5 Page Website Design
  • Unlimited Photo Galleries
  • Video Upload
  • Unlimited Slide Shows
  • PDF File Download

Website redesigns start at $595 and include all the features of a new website build. E-Commerce Websites are available at a reduced rate of $1,775, and, in addition to all the listed features for website design, includes a Shopping Cart System.

Website Hosting services are also available through Orangebook Website Design:

Basic Hosting ($37.50 a month)

  • 24/7 Web Maintenance
  • Unlimited Changes
  • SEO
  • Contact Management System

Premier Hosting Services ($89 a month)

  • Development of a Marketing Plan
  • Organic SEO
  • Content Development
  • Web Analytics and Analysis (evaluate weekly/monthly web traffic)

Orangebook Website Design provides personal website design services and has a portfolio of current websites, which include a wide variety of industry. Contact Orangebook Website Design at 949-715-5676 to further discuss the C.A.B. Consulting and Brokerage Website Design Discount.

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(3) bills already posted ahead of the 85th Texas Legislative Session

(3) bills already posted ahead of the 85th Texas Legislative Session

by The CAB Man Texas on January 6, 2017

The 85th Texas Legislative Session starts on Tuesday, January 10, 2017.  At this point, (3) bills have been posted ahead of the session.  See below for information on the bills as well as a few comments.

Ramon Romero (D): HB 60

Relating to requiring a credit access business to verify the vehicle identification number used to obtain a motor vehicle title loan.  Before obtaining a title loan for a consumer, to physically inspect the vehicle used as collateral, photograph the vehicle identification number, and verify that the number matches the number on the title provided by the consumer. Requires the CAB to retain the photograph until the second anniversary of the date the extension of credit is made.

Comments:  This really is something that any decent operator will do anyway. Not sure why additional regulation is needed here.  CABs have a very long list of regulations they abide by so why is Mr. Romero wanting to add more?

 

Matt Schaefer (R): HB 153

Relating to the authority of a municipality to regulate occupations.  Prohibits a municipality from adopting any ordinance that: (1) establishes additional, more stringent licensing requirements for an occupation that requires an occupational license issued by a state licensing authority, or (2) requires a person to obtain an occupational license issued by the municipality. Provides that any ordinance violating this prohibition is void.

Comments:  Anything that will void the city ordinances related to payday, installment, and auto title loans makes sense.  The city ordinances have caused over 1,500 businesses to close and have caused thousands of people to lose their jobs who worked at those stores.  With the increased cost of doing business that resulted from trying to survive the ordinances, CAB owners had no choice but to increase rates and that has hurt consumers – it was that or go out of business.

 

Diego Bernal (D): HB 197

Relating to contracts and other documents issued by credit access businesses.   Requires the contract and other documents provided by a CAB to be: (1) provided before signing written in both English and Spanish, (2) written in plain language, and (3) printed in an easily readable font and type size. Requires the Finance Commission to adopt rules implementing this provision. Requires the CAB disclosure and notice to be available in both English and Spanish at each CAB business location.

Comments:  CAB consumer loan document packages are typically 25 pages – if you have to create document package in both languages that will be 50+ pages of documents, tons of ink, paper, and toner.  That will mean an increase in costs and slower processing times which will be a major concern for business owners and an inconvenience for the customer, and likely even higher rates.   Who decides what “plain” language is? Will all the current document packages have to be re-written?  What is “reasonable” font size?  I know 12 point font is required in the TILA disclosures but due to all the regulations and other disclosures that are required to be provided, CABs (and other entities like banks) need to shrink font as small as possible so the documents aren’t too long.  (remember 25 pages+ to start).  If you go 12 point font on a document that is mostly 8 point font it is going to cause the document to double in size.  50 pages in English, 50 pages in Spanish!  And, the CAB has to make copies of the signed loan documents for their files so that becomes 200 pages!  All that for a $300 loan?  If this one passes we should all get into the paper, ink, and toner business!

 

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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CAB Consulting – Mid-Year Review and Going Beyond Licensing and Compliance

CAB Consulting – Mid-Year Review and Going Beyond Licensing and Compliance

by The CAB Man Texas on August 8, 2012

Hello and thank you for visiting www.CreditAccessBusiness.com!

We are now in the back half of 2012 and it has been a great year so far. January 1st marked the beginning of a new age in the Texas payday and auto title loan business and I want to thank each of for the trust you have placed in CAB Consulting. CreditAccessBusiness.com has become a highly visited site and our traffic continues to grow. CAB Consulting is pleased to be the resource for all things CAB in the State of Texas and we look forward to keeping valuable content on the site.

CAB Consulting is inviting site visitors, clients, and persons with industry experience to participate in our “Client Survey.” The survey’s intent is to assess current needs, gather perspective on the industry from operators, and get a report card from you on CAB Consulting so far.

The information you provide will be used as we all move forward and set our sights on continued growth and success. New programs are being developed that will be offered up for consideration soon, and part of the purpose of the survey is to get a sense of whether the new programs have the right priorities. Information shared will be kept private, not be made public, and will be handled with highest professional regard.

Click here to take survey

As always, feel free to contact Michael Brown of CAB Consulting at 214-293-8676 or via email at Michael@CreditAccessBusiness.com.

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Bank Fees are rising and so is use of Alternative Financial Services – coincidence?

Bank Fees are rising and so is use of Alternative Financial Services – coincidence?

by admin on August 14, 2012

I was reading this CNN Money.com article today: http://money.cnn.com/2012/08/13/pf/bank-fees-rise/index.html

This is an issue that I am very familiar with and the result is more customers for Texas Credit Access Businesses.

Monthly service fees on accounts with balances below $5,000 are the banks targets for the monthly service charges, which certainly fits the low and middle income profile of the typical payday consumer. And, don’t forget that NSF and Overdraft fees at many banks are have drifted up into the $35-$40 range.

Options like pre-paid debit cards are becoming more attractive compared to the bank branch, and in many cases the pre-paid cards offer more ideal online account management and smart phone capability, all with lower monthly service charges.

Consumers are learning there are more convenient and less costly options out there, and a migration towards cutting edge alternative financial services is happening. Shape your business accordingly, get creative, and stay convenient!

I refer to the information below very often in conversations – it is published by FISCA and illustrates the real deal on banking related charges versus payday advances – the APRs are less in many cases! Be sure and have these statistics ready the next time the APR topic comes up – and then nail it.

$100 Payday Loan (14 days) = $22.88 Fee (596% APR)
$100 Overdraft Protection = $29.00 Fee (756% APR)
$100 Bounced Check = $54.87 Fees (1,431% APR)

Sources:
(1) Bankrate.com, 2007 Courtesy Overdraft Study – based on average first draft
(2) Average NSF fee $28.23 (Bankrate.com, 2007 Checking Study), based on average first NSF charge, and average merchant return check fee of $26.64 (2006 CFSA fee survey).

{ 1 comment… read it below or add one }

Jer – Trihouse August 22, 2012 at 8:07 pm

Michael,

You made some great points in this piece. Too bad the regulators are not informed. Not only do bank NSF fees translate into higher APR’s than payday loan products but additionally, more than a few banks (Wells Fargo for example) are offering products that compete directly with payday loans. The banks debit these customers the moment their customer’s payroll check is deposited; NO RISK to the bank!

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Texas Credit Access Business CAB Information

CAB Packet

The CAB Packet contains the basic information needed to start the licensing and compliance transition process. Ordering this packet from C.A.B. Consulting and Brokerage will assemble all necessary elements to begin the transition process, eliminating the need to go to more than one place for initial information, guidance, and paperwork. The packet materials are offered in print and online for our client’s reference when needed.

Summary of included items:

•Transition process summary and opinion letter with important information related to the new license and licensing process
•Compliance summary and opinion letter with important information related to notices and disclosures
•Reference copies of important laws and regulatory publications
•Rules summary with interpretation and comments
•License application documents
•Inclusion of company members to the CAB Consulting and Brokerage Newsletters, Emails, and RSS Feeds

C.A.B Consulting and Brokerage does advise clients who purchase this packet that further research will be necessary and seeking the consultation of an attorney who specializes in the payday loan industry is recommended.

To learn more about details and specifics of this package, contact C.A.B Consulting and Brokerage at cabconbrokerage@gmail.com or call 214.293.8676.

 

Texas CAB Credit Access Business Solutions

Lenders

With over 3,000 registered payday loan businesses and 25 million people, Texas represents one of the most prolific markets for Lenders in the industry. One significant reason for this is the state’s licensing structure, called the “CSO Model” or “CAB Model.” You can read more about each of these models on our web-site’s “CSO – Old Way” and “CAB – New Way” pages.

The model requires that Credit Services Organizations (CSO’s), and Credit Access Businesses (CAB’s) operate alongside the 3rd Party Lender who provides the funds for loans to consumers.

Yes, despite the fact that many CSO’s and CAB’s do have the assets for loan funding they can never be used for that purpose, and arm’s length relationships with other entities must be established to play that role if they wish to participate in the robust Texas market.

In the arrangement, a CSO or CAB functions as a broker who markets its services, administers the loan process, and assists the consumer in attaining the loan much like a co-signer.

The 3rd Party Lender’s role is often a silent and secure one.  Interaction with the customer is rare, and it is common for the Lender’s proceeds to be guaranteed by the CSO / CAB with collateral in a number ways.

Are you a CSO or CAB that needs a Lender?

Have the new requirements and rules related to the Credit Access Business licensing process forced you to seek another Lender?

Are you interested in exploring the opportunities available to investors serving as Lenders in the CSO / CAB Model?

Call or email C.A.B. Consulting and Brokerage for details!

 

Texas Payday Loan Businesses – Take a CAB!

Texas Payday Loan Businesses – Take a CAB!

by The CAB Man Texas on September 2, 2011

What is a CAB?  Well, if you are a payday loan business in Texas, it’s now you starting January 1, 2012.

The title CAB stands for Credit Access Business, and along with the name change comes many changes for payday loan businesses. The current CSO (Credit Services Organization) model will evolve next year thus transitioning all payday loan businesses into CABs, which requires these businesses to comply with new regulations. Understanding the new regulations is vital to continuing your payday loan business.

Licensing is one portion of the CAB transition. Under Texas House Bill 2594, which addresses the new licensing process, current CSOs will be required to attain a CAB license and will be subject to a thorough review.   Applicants will undergo reviews not just of their business operation, but also of the principals involved with the CAB’s whose personal and business background will be requested.

What else is included in the CAB licensing process? A new application and detailed reports must be submitted to the state and an approval must be obtained in order for current businesses to operate legally after January 1, 2012. In addition, all Texas payday loan businesses must file quarterly reports, with the first being due April 2012.  The reports will summarize the prior three months of transactions and will be reviewed by the OCCC (Office of Consumer Credit Commissioner), which is the new governing body of the industry in Texas.  This process is new, it is an unknown, and will take some thought.  Are you ready to take this on?  In addition to the day-to-day operations of your payday loan business, you must create a plan to ensure compliance with the OCCC, which is a big undertaking.

The good news? CAB Consulting and Brokerage understands all the details required for your payday loan business to transition from a CSO to a CAB.  They’ve been in the payday loan business since 2003 and have recently participated in the rule making process at the Capitol in Austin to ensure thorough understanding of the CAB model and to voice preferences and concerns about proposed rules.

Don’t get bogged down by the details – contact CAB Consulting and Brokerage at 214-293-8676.   Let them inform you, handle the details of your transition, and execute the process so you can continue to do business in Texas.

Check back in for details about the new notices and disclosures requirements under the new CAB regulations.

{ 4 comments… read them below or add one }

Randy Olson May 1, 2013 at 10:59 pm

could you please send me some info about how we go about getting a loan office for Pay Day type loans started ? What license and how to apply would we need for Kerrville, Texas? What type of rules do we need to follow for our loans and where do we get a example of the contracts?
Thank you for any help you can give us.
Randy Olson

Reply

admin August 10, 2013 at 7:43 am

Hi Randy,

Congrats on your new biz. We’ve got sample docs, forms, and know-how for this. My team is focused on Texas payday ans car title loans.

Call me at 214-293-8676 Michael

Reply

Don Dunlap August 9, 2013 at 2:33 pm

I am brand new at this business idea and would like start up consulting advice

Reply

Anonymous August 10, 2013 at 7:38 am

Give us a call,Don. PH# on my web site

Reply

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Texas Payday Loan Businesses – Take a CAB!

Texas Payday Loan Businesses – Take a CAB!

by The CAB Man Texas on September 2, 2011

What is a CAB?  Well, if you are a payday loan business in Texas, it’s now you starting January 1, 2012.

The title CAB stands for Credit Access Business, and along with the name change comes many changes for payday loan businesses. The current CSO (Credit Services Organization) model will evolve next year thus transitioning all payday loan businesses into CABs, which requires these businesses to comply with new regulations. Understanding the new regulations is vital to continuing your payday loan business.

Licensing is one portion of the CAB transition. Under Texas House Bill 2594, which addresses the new licensing process, current CSOs will be required to attain a CAB license and will be subject to a thorough review.   Applicants will undergo reviews not just of their business operation, but also of the principals involved with the CAB’s whose personal and business background will be requested.

What else is included in the CAB licensing process? A new application and detailed reports must be submitted to the state and an approval must be obtained in order for current businesses to operate legally after January 1, 2012. In addition, all Texas payday loan businesses must file quarterly reports, with the first being due April 2012.  The reports will summarize the prior three months of transactions and will be reviewed by the OCCC (Office of Consumer Credit Commissioner), which is the new governing body of the industry in Texas.  This process is new, it is an unknown, and will take some thought.  Are you ready to take this on?  In addition to the day-to-day operations of your payday loan business, you must create a plan to ensure compliance with the OCCC, which is a big undertaking.

The good news? CAB Consulting and Brokerage understands all the details required for your payday loan business to transition from a CSO to a CAB.  They’ve been in the payday loan business since 2003 and have recently participated in the rule making process at the Capitol in Austin to ensure thorough understanding of the CAB model and to voice preferences and concerns about proposed rules.

Don’t get bogged down by the details – contact CAB Consulting and Brokerage at 214-293-8676.   Let them inform you, handle the details of your transition, and execute the process so you can continue to do business in Texas.

Check back in for details about the new notices and disclosures requirements under the new CAB regulations.

{ 4 comments… read them below or add one }

Randy Olson May 1, 2013 at 10:59 pm

could you please send me some info about how we go about getting a loan office for Pay Day type loans started ? What license and how to apply would we need for Kerrville, Texas? What type of rules do we need to follow for our loans and where do we get a example of the contracts?
Thank you for any help you can give us.
Randy Olson

Reply

admin August 10, 2013 at 7:43 am

Hi Randy,

Congrats on your new biz. We’ve got sample docs, forms, and know-how for this. My team is focused on Texas payday ans car title loans.

Call me at 214-293-8676 Michael

Reply

Don Dunlap August 9, 2013 at 2:33 pm

I am brand new at this business idea and would like start up consulting advice

Reply

Anonymous August 10, 2013 at 7:38 am

Give us a call,Don. PH# on my web site

Reply

Cancel reply

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3rd Party Lender

3rd Party Lender

With over 3,000 registered payday loan businesses and 25 million people, Texas represents one of the most prolific markets for Lenders in the industry. One significant reason for this is the state’s licensing structure, called the “CSO Model” or “CAB Model.” You can read more about each of these models on our web-site’s “CSO – Old Way” and “CAB – New Way” pages.

The model requires that Credit Services Organizations (CSO’s), and Credit Access Businesses (CAB’s) operate alongside the 3rd Party Lender who provides the funds for loans to consumers.

Yes, despite the fact that many CSO’s and CAB’s do have the assets for loan funding they can never be used for that purpose, and arm’s length relationships with other entities must be established to play that role if they wish to participate in the robust Texas market.

In the arrangement, a CSO or CAB functions as a broker who markets its services, administers the loan process, and assists the consumer in attaining the loan much like a co-signer.

The 3rd Party Lender’s role is often a silent and secure one.  Interaction with the customer is rare, and it is common for the Lender’s proceeds to be guaranteed by the CSO / CAB with collateral in a number ways.

Are you a CSO or CAB that needs a Lender?

Have the new requirements and rules related to the Credit Access Business licensing process forced you to seek another Lender?

Are you interested in exploring the opportunities available to investors serving as Lenders in the CSO / CAB Model?

Call or email C.A.B. Consulting and Brokerage for details!

{ 1 comment… read it below or add one }

Magda Oviedo August 19, 2016 at 2:15 am

I am looking into starting a CSO business primarily focused on home mortgage lending/refinancing. I wonder if a home based business is a good way to start since I do not have access to much capital. I also need a source of income soon due to being unemployed at the moment. I recently resigned from my 9 year Spanish teacher position.

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OCCC Examinations in Full Swing

OCCC Examinations in Full Swing

by The CAB Man Texas on May 11, 2012

Good afternoon Credit Access Business World!  For those of you who are out and about on the internet today doing a little research on OCCC CAB Compliance, OCCC Audits, Credit Access Business licensing, etc, you most likely will happen upon this blog post.  I have been working with Credit Access Businesses on their compliance, the OCCC quarterly reports, and examination preparation.  Over the last few weeks there has been a definite up-tick in word on the street about the “Audit.”  The OCCC is calling them “Examinations” and they began in mid-April.

In December 2011, I met with the OCCC and was given some hi-lights of what an examination would be focused.  My recommendation is that you focus on Chapter 393 of the Texas Finance Code, HB 2592, and HB 2594.   Make sure your loan contracts include all recommended and required disclosures, and be ready to have files reviewed.  It is possible that a CAB be asked to refund some or all fees collected in 2012 if certain violations occur.  So, the price is high for non-compliance and sloppy documentation.

If you have doubts, there are many options out there, contact the OCCC or CAB Consulting and Brokerage, get with attorneys who are experienced, or reach out to friendly competitors.  The small to mid-size operators might be in harm’s way as they are not traditionally the ones with consultants, on staff attorneys, etc.  So if you are one who fits that profile – now is the time to invest in your business, take the time to do your research, or hire someone to review it.

If you are licensed you will be examined, and it is typical for the OCCC to simply show up at your store with no prior notice.   Call Michael Brown at CAB Consulting and Brokerage, we can discuss options and get going on a plan.  Michael can be reached at 214-293-8676, or via email at cabconbrokerage@gmail.com.

 

{ 1 comment… read it below or add one }

Tangela Taylor September 8, 2016 at 12:40 am

Need to know your costs for getting the OCCC License completed.
Please call me at 214-207-7496

Reply

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