Texas CAB Licensing Update – Transition to NMLS
• Creation of individual NMLS accounts for owners, control persons, and other required individuals
• Addition of branch locations (if applicable)
• Assignment of branch managers
Call: 214-293-8676
The Fed says nearly 4 in 10 Americans lack enough money to cover a $400 emergency expense
A fellow Texas CAB and TOFSC Member shared this article with me today that was featured on Fortune.com. For those of us operating in the short term small dollar loan industry offering payday loans or auto title loans we know that having as much as $400 set aside for emergencies is damn good compared to the 18% of folks that don’t have $100. Based on the stats quoted in the article if 37% of Americans don’t have $400+ cash reserve that comes to 123 million people, the 18% with less than $100 comes to 60 million people. Those numbers are sobering. With savings continuing to drop, some might say it is common sense to make sure there is growing access to credit for US consumers. The more access to credit the better – let a wide-open market compete and let the consumers choose what works best for them in that moment.
Here’s the link to the article:
Nearly 4 in 10 Americans can’t cover a $400 expense, Fed data shows | Fortune
CFPB’s 16th Monthly Complaint Report released on October 25, 2016.
CFPB’s 16th Monthly Complaint Report released on October 25, 2016.
I always look forward to the new CFPB complaint reports that come out each month around the 25th. Why? Well as you will see if you follow them as well, the “Payday Loan” industry (this is the umbrella term used in these reports to refer to companies who offer payday loans, installment loans, title loans, cash advances, etc) has yet another double digit decrease in complaint volume versus the same 3-month period (July-August-September) last year. This month showed a 21% decrease.
It is unfortunate that there were complaints, and I can tell you that our clients would be extremely concerned in the event any complaint was filed by their customer. They would respond promptly and work to communicate with the customer to clarify any misunderstandings and work out a resolution. Zero complaints – that is the goal.
As is the case with the other monthly reports – we are always the industry with the largest decrease. There are 10 other industry categories and we are the only one with these giant drops in customer complaints, consistently. Student loans are #1 and our bank friends are at #2 with a 37% increase.
I am aware that consumer advocates and others who are not so friendly to the industry visit this website. I am wondering if they also view the CFPB complaints each month. The story being told here is that consumers complain less about our services than any CFPB category. I would recommend you shift your focus to the biggest offenders if you are currently hyper-focused on shutting down the “payday loan” industry.
After all the work you have done to work up complaints you have only mustered a double digit decrease in complaint volume, you may be able to do better somewhere else. I think the banks are where you should go – they target our customers with abusive overdraft charges and NSF fees with astronomical effective APR’s (think 1,600.00%), and bring in about 4 times the amount of annual revenue that our industry does.
Here is the link to this month’s report (see page 4):
CFPB October 2016 Monthly Complaint Report
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.
Previous post: Everything is bigger in Texas!
Next post: Fun with the filing of liens on Motor Vehicles in Texas.
Fun with the filing of liens on Motor Vehicles in Texas.
Fun with the filing of liens on Motor Vehicles in Texas.
Dealing with Texas DMV office who refuse to allow Credit Access Businesses to add a lien to a vehicle (for a Title Loan) when the registered owner of the vehicle has outstanding warrants, tickets, toll fees and or recent child support payments on file as delinquent can be a problem. We have seen this in a few counties recently – it appears to be referred to as a “Scoff Law”.
The only fix we have seen that works is to simply process the lien in a different county. There are 254 counties in Texas, and each tend to do their own thing!
Another instance that has come up with some title loan borrowers is when one consumer who has a title loan with a CAB sells their motor vehicle to another consumer without the buyer getting the title. The buyer in these cases can either be tricked into doing this or may just be careless / unaware.
For the CAB in this case, because they actually have the title and the lien, they “own” the vehicle and would be forced to repossess if the seller stops paying on the loan (this would be what triggers awareness of any issue other than if the buyer comes back later and asks for the title).
If you find yourself in this predicament as a buyer or a CAB, follow the law and rely on other professionals to consult you on the best course of action. For CABs (as always) follow the proper disposition methods in compliance with Texas Business and Commerce Code Chapter 9.
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.
Leave a Comment
