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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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

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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

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2014 TOFSC Conference Invites have been sent!

2014 TOFSC Conference Invites have been sent!

by The CAB Man Texas on August 18, 2014

The 2014 TOFSC Conference invites were sent out today.  Looking forward to hearing from Members, Vendors, other other invitees on attendance.

Attendance forms were sent out on email, see below for that form if you did not receive one.  Send completed forms to Michael Brown via email or fax.  Michael@CreditAccessBusiness.com or 888-561-0986.

The conference will an afternoon event, will try and wrap up by 5pm then we can all head to have some cocktails and appetizers at the hotel after.

We will have a number of Sponsors who will address the group on issues to our Members.  I am looking forward to the event – will make sure everyone gets value out of your time at the conference.

Best,

Michael B.

And, here is the link to the invite:

TOFSC.Conference.Invite

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OCCC Compliance Basics from CAB Consulting

OCCC Compliance Basics from CAB Consulting

by The CAB Man Texas on June 27, 2017

Just a reminder for all of you CABs out there – continually review your Consumer Transaction Information Disclosures & Fee Schedules.

Many times throughout the course of the year CAB operators may change their CAB fee amounts or offer different loan products such as offering multi-payment installment loans, payday loans, or auto title loans.  When changes are made and loan  products are dropped, added, or modified, we have seen the Fee Schedule & Consumer Transaction Information Disclosures be overlooked.

Take the time to ensure that your Consumer Transaction Information Disclosures & Fee Schedule are up to date with all of the products you are offering.  This is on the OCCC Examiner Checklist and Examiners will call you out on this.  Be an “A” student and get it right.

Additionally, per Texas Administrative Code 83.5004, if changes are made to your Fee Schedule or Consumer Transaction Information Disclosure, preceded versions must be maintained on site for a period of one year or until the next OCCC examination.

Here is the exact language regarding the retention of amended Fee Schedules & Consumer Transaction Information Disclosures:

For In-Store Transactions:

“In-store fee schedule and notices. The in-store fee schedule and notices required by Texas Finance Code, §393.222(a), and §83.6003(a) of this title must be available for inspection by the OCCC in a conspicuous location visible to the general public. If a licensee amends the in-store fee schedule or notices, it must maintain documentation of the previous versions of the schedule or notices for one year from the date of amendment or until the next examination by OCCC staff, whichever is later. The licensee may maintain the documentation of previous in-store fee schedules and notices at a centralized location other than the licensed location or branch office. In this case, the documentation must be maintained for one year from the date of amendment or until the OCCC’s next examination of the centralized location, whichever is later. However, upon the OCCC’s request, the licensee must have the ability to promptly obtain or access copies of the complete documentation so that the OCCC can examine it.”

For Online Transactions:

“Website and online disclosures. If a licensee maintains a website, it must make the website available to the OCCC for inspection. The website must include a fee schedule to show the licensee’s compliance with §83.6003(b) of this title, and applicable consumer disclosures to show the licensee’s compliance with §83.6007(f) of this title. If a licensee amends the website’s fee schedule, consumer disclosures, or method of accessing the fee schedule or consumer disclosures, the licensee must maintain documentation of the previous version of the website to show compliance with §83.6003(b) of this title and §83.6007(f) of this title. This must include the home page, any pages used in accessing the fee schedule and disclosures, and copies of the previously used fee schedule and disclosures. The licensee must maintain this documentation for one year from the date of amendment or until the next examination by OCCC staff, whichever is later. This paragraph does not require a licensee to maintain previously used pages of the website that were not the home page or pages used in accessing the fee schedule and consumer disclosures. The licensee may maintain the documentation of previous versions of the website at a centralized location other than the licensed location or branch office. In this case, the documentation must be maintained for one year from the date of amendment or until the OCCC’s next examination of the centralized location, whichever is later. However, upon the OCCC’s request, the licensee must have the ability to promptly obtain or access copies of the complete documentation so that the OCCC can examine it.”

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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CFPB released a new kind of complaints report

CFPB released a new kind of complaints report

by The CAB Man Texas on June 19, 2017

After not being able to find the CFPB monthly complaint report on payday loans last week, I found it Wednesday which was a bit later than normal.  The delay might have been because it is a different kind of report, it is focused on “older” complainants who were 62+ years of age.

This new format report focused on just one month, and discloses that payday loan industry had (23) complaints versus (27) in the prior month.  That is a 28% decrease and is very much in line with all of the other reports that have been released I believe this is #23.

There have been 1,610 CFPB complaints submitted on the payday loan industry since complaints started being taken in November 2013, and (60) “older complaints” have been submitted since November 2013.

Overall, 1,163,000+ total complaints have been submitted so far to the CFPB covering all industries not just ours.  1,610 o, so PDL has a .001387931 complaint ratio!

Here is a link to the CFPB’s published report:

https://s3.amazonaws.com/files.consumerfinance.gov/f/documents/201705_cfpb_Monthly_Complaint_Report.pdf

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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Use the OCCC’s Alecs portal to file annual and quarterly reports

Use the OCCC’s Alecs portal to file annual and quarterly reports

by The CAB Man Texas on June 9, 2017

Did you know that the OCCC has added the capability of filing your Annual and Quarterly reports to the Alecs portal?  That is right, you no longer need to access the separate reporting area – everything you need is done right inside of your company’s Alecs portal.
Login to Alecs, click “Manage my Business” in the Nav Bar, then scroll down and to the right to “Annual/Quarterly Reporting.”  It is there that you can choose “upload report.”
Here is the link to the Alecs login – check it out:  https://alecs.occc.texas.gov/
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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Payday Lenders are Positioned to Excel in the New American Economic Reality

Payday Lenders are Positioned to Excel in the New American Economic Reality

by The CAB Man Texas on October 4, 2011

Recently, I wrote a blog that focused on Lender investment opportunities and strengths of the Texas payday loan market.  Today, I expand my optimism for the payday loan industry beyond Texas. In my opinion the entire payday loan industry is primed for success in today’s new economic reality.

Why?  Look at the economic times, and apply the advantages of the industry and its products.  Need cash now, not later? Check.  Do you have credit problems? Check.  Need flexible payments? Check.  The payday loan industry was born out of innovation and has evolved into a product that flourishes in a consumer market with high defaults, poor credit, and inconsistent payments.  Because of this fact, today’s payday loan option represents an open door when so many others are closed.

Given the additional fact that the American appetite for entertainment, food, and shopping isn’t exactly dying, the industry is in a favorable position, and it is in many ways a perfect storm of opportunity.  It is not about taking advantage of consumers, it’s about meeting a consumer need.

In what ways can our industry stakeholders go beyond the “Payday Loan” and create more value in their relationships with customers?  How can the bigger challenges that the industry faces like regulation and perception be overcome?  One industry leader I know is encouraging communication and the exchange of ideas to answer such questions.  Whoever gets it right will be catapulted into the new global economic reality where they will reap the benefits.

Are we living in a new America?  Yes, and we need to shed the old ways of thinking and get on with it.  China, India and other foreign markets are seizing the opportunity to make money in our country, while America appears to be stuck in the past and applying old fashioned business standards to a world that is no more.  Welcome to the future – it is here!

Instead of trying to get back to the good ole’ days, the innovators and bright minds of today see that the best days lay ahead.  I challenge you to be an innovator and seize the opportunity to lead our country into a new, boundless reality.

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Michael Brown takes the helm at TOFSC!

Michael Brown takes the helm at TOFSC!

by The CAB Man Texas on June 3, 2014

As of June 1, 2014 Michael Brown of CAB Consulting will be managing TOFSC         (http://tofsc.org/) and will no doubt be taking the organization to new heights!

The transition in ownership started mid-May and will run through June. Michael and Clay Chancey are working closely with one another to assure a smooth transition.

The future is bright for TOFSC! The organization will continue to communicate developments in the industry on a frequent basis, and it will also continue providing a platform for Texas CABs to interact with one another. Under new guidance, TOFSC will shape itself by listening to the needs of members, and by promoting concepts that will be aimed at their bottom line.

TOFSC areas of focus moving forward:

  • Increase membership and mobilize the group.
  • Provide frequent and meaningful communication.
  • Discuss innovative ideas and trends.
  • Surviving City Ordinances.
  • Increase communication with the OCCC.
  • Open forums and CAB Q&A sessions.
  • 2015 Texas Legislative session preparedness.
  • Community involvement.
  • CFPB Communications and Developments.
  • Vendors you need to know about.
  • Strategic Partnerships.
  • Capital and Third Party Lenders.

Please contact Michael with all questions or comments! He can be reached at 214-293-8676, or via email at: Michael@CreditAccessBusiness.com.

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