There’s decent list of new requirements that the Texas CSO needs to know about when they are applying for their new Credit Access Business license this fall.  Substantial input has been provided by many CSO’s in Texas as far as the new rules go, and recently I attended two stakeholder meetings in Austin at the Capitol Building to contribute my thoughts.

In the past I have not been to such a meeting and so I was all ears. At the beginning I wasn’t sure if the atmosphere was going to be contentious, if the members of the Finance Committee were going to be friendly, or if they were truly seeking input. I have heard of some heated confrontations on the House floor so I was kind of expecting the same. But, it was actually very co-operative, and the stakeholder input was asked for more often than it was given believe it or not.

From a high level – the OCCC is going to dig a little deeper this time around and take a close look at both sides of your business model versus your prior CSO application. Information about owners all the way down to 5% may be asked for, and they want important information for the lender as well.  Reports are going to need to be submitted quarterly, there are new ways that you must disclose information to consumers, and certain procedures will be required that have not been mentioned before.  And, there’s going to be several more fees charged to the licensee.

All in all, the forum in Austin was warm, and the word “flexible” was used often by the OCCC board members.  An example of the OCCC listening to stakeholder input and their being flexible was in regards to the request for Credit Access Businesses to provide their contract forms with their CAB application. This request was met with concern, the concern was expressed, and as a result the documents will not be required with the application.

October 21 is the next date CSO’s need to be aware of – OCCC will be firming up proposed rules and rules changes.  I will keep everyone posted on my blog – looking forward to your return.

Questions?  Feel free to call me! Michael Brown at C.A.B. Consulting and Brokerage (214-293-8676).