Author: Michael Brown

Texas CAB Licensing Update – Transition to NMLS

Posted on by Michael Brown
The Texas Texas Office of Consumer Credit Commissioner (OCCC) has officially shut down Credit Access Business (CAB) functionality in the ALECS system as part of the transition to the Nationwide Multistate Licensing System & Registry (NMLS).
 
CABs will begin the official transition process Monday, March 16.
 
For now, you can go here to access licensing documents and guidance on the NMLS transition: https://occc.texas.gov/industry/cab/licensing-forms/
 
A few important operational notes for the industry:
• If you were in the process of preparing a new CAB license application in ALECS but had not yet submitted it, those applications appear to have been deleted.
• If you currently have a CAB license application already under review, you will still be able to continue working through that application within ALECS.
• No new CAB license activity will be accepted in ALECS going forward.
 
Beginning March 16, all new CAB applicants will need to complete the entire licensing process through NMLS.
 
For existing CAB licensees, the transition application process will require several steps: • Creation of an NMLS company account
• Creation of individual NMLS accounts for owners, control persons, and other required individuals
• Addition of branch locations (if applicable)
• Assignment of branch managers
 
Each of these steps involves its own process of data entry, document uploads, and attestations to properly link all company, individual, and branch records within NMLS.
 
Another notable change: OCCC reporting will no longer occur through ALECS. At this time it has not yet been announced what system will ultimately handle CAB annual and quarterly reporting going forward.
 
For many of us who have worked in Texas consumer lending for years, ALECS has been a simple — if sometimes quirky — system. We learned its nuances, its shortcuts, and its occasional roadblocks.
 
Now we begin working inside NMLS… which of course has its own set of complexities.
 
CAB Consulting assisted many Regulated Lenders with this same transition last Summer and has already begun working with Texas CABs to get ready for this process. 
 
Reach out for more information see below for contact. Best,
 
Michael Brown
Principal: CAB Consulting
 
Email: Michael@CreditAccessBusiness.com
Call: 214-293-8676
 
 

The Fed says nearly 4 in 10 Americans lack enough money to cover a $400 emergency expense

Posted on by Michael Brown

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