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 a good position regarding software, APR% calculations, loan contracts, disclosures, and fee schedules.

That being said it is always good to get refreshers on where the OCCC may be looking the next time you come due for an examination.  If  you are in DFW, East Texas, or Houston I would make sure that you are ready to rock!

See below for some recent areas of emphasis:

• TILA – is your APR% exact?  Are you off slightly?  Needs to get fixed asap if you are even slightly under-quoting.  Contact your software company ASAP.
• Financial Privacy Act Notices – are the ones in your document package proper?
• Credit Services Disclosure Statement – regarding the time frame consumer have to ask for information – are you quoting the proper number of days?
• Updated OCCC Contact information – there was a change awhile back on this.  Did you update it?
• OCCC Notice – must be plain to see and easy to find 1-click from the home page of your website.
• Interest paid or to be paid to lender – this must also be disclosed on the Credit Services Agreement.
• When selling a motor vehicle that has been repossessed – how many bids are you getting?

If you would like additional information on these areas feel free to reach out!

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.