The Texas Payday Loan Ordinance suffers another blow, this time Abilene voted it down.

The Texas Payday Loan Ordinance suffers another blow, this time Abilene voted it down.

by The CAB Man Texas on May 12, 2017

Down goes another “payday down city ordinance! On Thursday, April 27th. 2017 the Abilene City Council did right thing and voted “NO” on the so-called “payday loan city ordinance.”

Things do not seem to be going very well for the payday loan city ordinance these days the truth is really starting to get out that it is not even being enforced and the courts have decided (in two separate cases) that it is pre-empted by State Law!

So, let’s talk about how this latest defeat of the payday loan city ordinance went down in Abilene.  First, I must say that I have been to many city council meetings to participate in the payday loan ordinance conversation and I have never seen so many customers turn out to tell a city council to stay out of their personal finance decisions.  Not only did they turn out in droves to the meetings but those who could not attend inundated the city council email in-boxes and phone lines with a strong voice saying – vote “NO” on the ordinance.

Dozens of customers attended both the city council meetings the week of the “NO” vote wearing white t-shirts with “Stop the Ordinance” on it, inside the shape of a big red stop sign.  Supporters of the ordinance had to have been very impressed by the sea of white t-shirts streaming into the council chambers while cameras were rolling.  I think there was a grand total of (1) customer who attended the meetings that supported the ordinance on the other hand.  But, our anti-ordinance customers stood tall and proud when they approached the microphone.  Nearly (30) anti-ordinance supporters attended in their “Stop the Ordinance” gear, and the total for the two meetings had to have been way above that.

Those payday and auto title loan borrowers in attendance were there to tell the council to vote “NO,” to share their reasons for borrowing, and to vent their frustration that they could be possibly have their financial choices severely damaged by a reckless city ordinance that is a complete failure in 41 other cities in Texas.  In the end, it was the voice of those customers that stood proud and tall to defend themselves that swayed the city council to refuse to pass the ordinance.  I can remember the moment Councilman Shane Price held up the stack of comments he received and printed out from his email.  The vote “NO” stack was inches thick and the stack of comments from those who supported the ordinance was quite light.  In the end, he said that is what mattered.

What an empowering experience for many of these folks to go down to the formal and intimidating City Hall and have their voice heard.  The customers stood strong in the face of Newspaper reporters, TV cameras, and the breathless consumer advocate groups who were there to insult them and suggest they were not intelligent enough to manage their own finances.

I could see how those supporting the ordinance began to place pressure on city council, how they began to burden the council with solving the much larger issue that is at the core of the need for short term small dollar loans.  That is the fact that many Americans simply do not have enough money saved to fall back on in the event of an emergency or other problem in life.  70% of Americans do not have over $1,000 in their bank account – this is the problem.  The supporters of the payday loan ordinance were trying to sell the council and get them to pass an ordinance that would raise payment amounts, close businesses, and do nothing to impact that core issue.

I was talking with a customer of ours at the meeting and we were joking and wondering if the next ordinance to be rolled out would restrict Whataburger from selling hamburgers with meat in them so the Abilene City Council can end all heart attacks in city limits. Can you imagine this?

“Hey, Whataburger, yeah, we are not saying we want to put you out of business, but um, yeah we can’t allow you to actually put meat on your burgers anymore, because, you know, it uh, causes heart attacks and you are a terrible person too by the way, but we just want to protect our citizens from your predatory burger making practices with some thoughtful restrictions on fast food hamburgers…oh and burgers can still be sold at real restaurants though, they can still sell hamburgers it is just your kind of hamburgers that we don’t like, yeahhh.” 

It was hilarious, but quite honestly from our standpoint the payday loan ordinance is just as absurd.  The payday loan ordinance is a misguided disaster that is going to continue to unravel.  What the consumer advocate groups and church groups cannot grasp is the fact that the city ordinance does not achieve what they say they want.  It is a gigantic lie that has been perpetrated in 41 cities.  Their (mostly Texas Municipal League and Texas Appleseed) technique to get the ordinances passed has worked in those cities where council members do not do their homework, believe in a lot of regulation, or just want the businesses to go away.  But, their tired argument has grown stale, the final blow appears to be that cities are losing court cases over it, and cities are now voting it down.

Consumer advocates and church groups have their hearts in the right place but are choosing wrong vehicle to help solve what is a much larger problem than the short term small dollar loan industry.  I mean, unless you just did not do the math on how the 25% rule in the ordinance works, how can you ask the city council to approve an ordinance that will raise a borrower’s payment amount?  That fact alone should have caused the ordinances to get dumped in the trashcan two minutes after Texas Appleseed comes strolling into a city council person’s office.

Texas Appleseed – did you know payday transactions have hovered at the same level statewide even with a 41% decrease in stores?  Is the ordinance really the ideal vehicle for your cause?  If you want to do some more good, why not help communities apply for for a $30,000 grant from the Texas Educational Endowment Fund (http://occc.texas.gov/consumers/texas-financial-education-endowment-tfee-grant-program) to start financial education in the schools in your town instead?  This fund is completely funded by Credit Access Businesses to the tune of $400,000 per year (roughly).

The bad news regarding the TFEE is that Texas Appleseed and TML’s efforts resulted in the closure of 1,400+ locations which caused contributions to the TFEE to fall through the floor.  In 2013, the annual contribution amount was more like $700,000 per year.  $300,000 less per year is an insane amount of money that they took away from some groups that could have made a difference for the same people you are trying to help.

Also, the OCCC has taken a huge hit on licensing revenue that they could have used to hire new examiners to enforce the regulations already in place statewide.  Licensing fees are $600 per year per location, with 1,400 less locations in 2017 versus 2013 that comes to $840,000 less in licensing revenue per year.

Between the loss in TFEE contributions and the loss of OCCC licensing revenue that adds up to millions of dollars you have caused to evaporate from places that could have helped the consumers you are trying to protect.

To Churches and other groups besides TML and Texas Appleseed that have chosen to pile onto this issue when the issue comes up at city council meetings – why not just payoff all the loans that people take out with your own money?  Or why not just offer them a loan at 10% APR yourselves?  Stop asking the city fix the problem with a lousy ordinance and fund some loans yourself!

Long blog and I could go on about this for days, but I am going to wrap this up and save my energy for the next city that wants to look at the payday loan city ordinance.  I will conclude with another thank you to all the people that worked hard in Abilene to get the “NO” vote and again say how much we appreciated the opportunity to tell our side of the story to a city council who really committed to doing their research on this issue.

If you would like to read about what happened in Abilene here are a couple links to news on the “NO” vote that we were so thankful for:

http://www.reporternews.com/story/news/local/2017/04/25/payday-loan-debate-rages-abilene-city-council/100906592/

http://www.ktxs.com/news/citizens-voice-opinion-about-payday-lending-ordinance/449890488

http://www.bigcountryhomepage.com/news/abilene-city-council-rejects-regulating-payday-loan-businesses/700635585

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

Currently you have JavaScript disabled. In order to post comments, please make sure JavaScript and Cookies are enabled, and reload the page. Click here for instructions on how to enable JavaScript in your browser.

Previous post:

Next post:

Texas OCCC issues advisory bulletin to licensees on how to remain in compliance while dealing with Harvey aftermath

Texas OCCC issues advisory bulletin to licensees on how to remain in compliance while dealing with Harvey aftermath

by The CAB Man Texas on September 8, 2017

Our friend ROb Norcross at CSAT sent over some really good details that he had gathered in response to the OCCC issuing advisory bulletins to licensees on how to remain in compliance while dealing with Harvey aftermath.  I scraped some of those details and organized them below for CAB stakeholders in Texas, and business owners in general that were affected by Harvey.

CAB Consulting and TOFSC have clients and Members in the Coastal region and many were impacted – see below!

“The Texas Office of the Consumer Credit Commissioner issued an advisory bulletin reminding pawn shops of their obligations in statute and rule about safeguarding pledged goods, record retention requirements and relocating to temporary locations (see link in the email below). 

There are no similar provisions in Texas Finance Code Chapter 393 for credit access businesses. Sections 83.308 (b) and (c) in Title 7, Part 5 of the Texas Administrative Code addresses the relocation of transactions from one store to the other Section (c). Section (b) contains the notice requirements for customers and to the OCCC. Section (c) also provides for a waiver of the 5 day notice period by the Commissioner in cases of emergency. 

If one of your stores is damaged, and you choose to send customers to other nearby stores, please take care to follow these procedures. The provisions of your contracts with your customers will govern issues related to due dates, fee calculations, etc. 

The Code prohibits the relocation of a CAB store unless 30 days’ notice is given to the OCCC. There is no waiver provision for an emergency. However, if one of your stores — that is not near another store — is damaged, please contact the OCCC if a temporary location is the only reasonable solution to protect your customers. Despite the absence of a waiver provision in the statute, the OCCC has made reasonable accommodations to protect consumers with all types of licensees in the case of emergency. 

County Sheriff’s Office

If one of your employees has a question about local hurricane relief activities, law enforcement procedures during/after a hurricane, customers applying for federal assistance, shelter availability, etc., please do not hesitate to contact the local county sheriff’s department. Sheriff’s offices are a critical source of information during disaster recovery efforts. They are trained to navigate the varying levels and overlaps of local, state and federal bureaucracy and often serve as a counties’ switchboard during disaster recovery.

Do not spend hours on the telephone being transferred from FEMA official to FEMA official — call your local county sheriff’s office. They will (literally) tell you where to go…

 IRS Extends Filing Deadlines for Hurricane Harvey Victims

The Internal Revenue Service is giving Hurricane Harvey victims extra time to file individual and business tax returns and to make certain tax payments in 18 Texas counties because of the “devastating storm.” Businesses and individuals affected by making quarterly estimated tax payments on September 15th and January 16th now have until January 31st to file tax returns and pay taxes that were during those times. 

Vehicle Titling and Registration Requirements Suspended 

Texas residents in counties impacted by Hurricane Harvey will not have to worry about vehicle titling and registration requirements for the next 45 days. Governor Greg Abbott suspended certain statutes related to the enforcement of title and registration laws in the 58 counties included in the state’s disaster declaration. 

Customer Inquiries to the OCCC

We are working closely with the Office of the Consumer Credit Commissioner to help them process questions received from customers efficiently. Every CAB transaction contract, and most disclosures, include the name, telephone number, and the email address of the OCCC. 

Every time a consumer makes a complaint to the OCCC, the agency is required to open a file, contact the consumer, contact the CAB/lender, make a determination about a resolution for the complaint, and notify both parties in writing before closing the file.

However, after natural disasters, the agency typically receives questions from consumers in addition to complaints. If your company would like to designate a point person to address questions the OCCC may receive from your customers, please let me know. 

We will give the OCCC the name, telephone number and email address of your designee so the OCCC can refer questions directly to you. We want to give the OCCC every incentive to treat as many inquiries as questions, and not complaints (and staff prefers to open as few complaint files as possible). 

Texas Association of Business Hotline

TAB has established a hotline for businesses to connect to the resources they need as rebuilding begins. The hotline number is 512-637-7714. The hotline is available to all businesses. It is not limited to TAB members. You can also sign up to provide services as rebuilding begins in southeast Texas. For more information, visit: www.texbiz.org/2017/08/25/hurricane-harvey/.”

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

Currently you have JavaScript disabled. In order to post comments, please make sure JavaScript and Cookies are enabled, and reload the page. Click here for instructions on how to enable JavaScript in your browser.

Previous post:

Next post:

OCCC Examinations in Full Swing

OCCC Examinations in Full Swing

by The CAB Man Texas on May 11, 2012

Good afternoon Credit Access Business World!  For those of you who are out and about on the internet today doing a little research on OCCC CAB Compliance, OCCC Audits, Credit Access Business licensing, etc, you most likely will happen upon this blog post.  I have been working with Credit Access Businesses on their compliance, the OCCC quarterly reports, and examination preparation.  Over the last few weeks there has been a definite up-tick in word on the street about the “Audit.”  The OCCC is calling them “Examinations” and they began in mid-April.

In December 2011, I met with the OCCC and was given some hi-lights of what an examination would be focused.  My recommendation is that you focus on Chapter 393 of the Texas Finance Code, HB 2592, and HB 2594.   Make sure your loan contracts include all recommended and required disclosures, and be ready to have files reviewed.  It is possible that a CAB be asked to refund some or all fees collected in 2012 if certain violations occur.  So, the price is high for non-compliance and sloppy documentation.

If you have doubts, there are many options out there, contact the OCCC or CAB Consulting and Brokerage, get with attorneys who are experienced, or reach out to friendly competitors.  The small to mid-size operators might be in harm’s way as they are not traditionally the ones with consultants, on staff attorneys, etc.  So if you are one who fits that profile – now is the time to invest in your business, take the time to do your research, or hire someone to review it.

If you are licensed you will be examined, and it is typical for the OCCC to simply show up at your store with no prior notice.   Call Michael Brown at CAB Consulting and Brokerage, we can discuss options and get going on a plan.  Michael can be reached at 214-293-8676, or via email at cabconbrokerage@gmail.com.

 

{ 1 comment… read it below or add one }

Tangela Taylor September 8, 2016 at 12:40 am

Need to know your costs for getting the OCCC License completed.
Please call me at 214-207-7496

Reply

Leave a Comment

Currently you have JavaScript disabled. In order to post comments, please make sure JavaScript and Cookies are enabled, and reload the page. Click here for instructions on how to enable JavaScript in your browser.

Previous post:

Next post:

Information for Texas CSO’s on Credit Access Business licensing

Information for Texas CSO’s on Credit Access Business licensing

by The CAB Man Texas on September 13, 2011

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).

 

{ 2 comments… read them below or add one }

Luis g Garcia May 21, 2013 at 4:40 am

I need info about the CAB licence what the cost you charge for this license I ready to open Mr title loans and pay day loans en eagle pass tx but I need you help to fix the premises or licenses

Reply

admin August 10, 2013 at 7:41 am

214-293-8676 call us first for an exploratory call

Reply

Cancel reply

Leave a Comment

Currently you have JavaScript disabled. In order to post comments, please make sure JavaScript and Cookies are enabled, and reload the page. Click here for instructions on how to enable JavaScript in your browser.

Previous post:

Next post:

Silicon Valley FinTech “Earnin” may need to buckle up for a bumpy ride.

Silicon Valley FinTech “Earnin” may need to buckle up for a bumpy ride.

by The CAB Man Texas on September 11, 2019

The New York Times ran a bit of an “expose” on “Earnin,” an online lending FinTech that may need to buckle up for a bumpy ride…

It seems like each week there is a new Silicon Valley FinTech anti-payday loan venture that is launched with millions in funding and all the slick PR you can buy. There is a formula to the launches, and most have the disruptor mindset but at first glance to many observers, it is clearly a well disguised online payday loan business. It was stated in the Post’s article that Earnin has an $800 million valuation – how much of that do you think came from being hyped by the media? Funny thing is, much of the media that promotes these startups don’t do their homework and would tell you they despise the payday industry if you asked them. Imagine that!

Earnin has been around for several years now and the “tip” model they use is now coming into question. They don’t charge a fee for the loan they just say “tip us if you liked it” or something along those lines. The New York Post says Earnin “has been scrambling to escape regulatory heat over concerns that it has been doing illegal payday lending in the Big Apple.”. It was surprising to read that the tips being collected were $14/$100 per week.  That comes to $28/$100 for two weeks. In Texas the average fee range per $100 borrowed is $20-$25/$100 so that tip is really popping up on some radars now. When you calculate the APR on $28/$100 that is getting into the 600%+ APR range which will typically cause a left leaning liberal with consumer advocacy on their mind to simultaneously combust.  
 
Now, the New York Department of Financial Services appears to be one of those who are very hot under the collar over Earnin doing transactions with New Yorkers. As well, 11 other states are investigating Earnin for violating usury laws. New York sent a subpoena to Earnin in March, shortly after that the tip feature was turned off for New Yorkers. Earnin is now having to explain the switch off, and that loan amounts were not driven down by poor tippers which looks very bad. There were some leaks from former employees apparently. In one of those leaks “Earnin also considered going after perceived enemies. One employee suggested the company hire a private investigator to look into The Post reporter who had written the story” about them. Whoa – this is getting good!

We’ll see how it all plays out, Earnin seems to be getting lined up for a major hit on the chin for other FinTech lending disruptors with similar shell game models. Those who are out in front as Earnin has been, often times are going to have to survive the legal battles to prove out the model while others who are not quite so visible, lay low and quietly ride out the process.

Here is a link to read more from the New York Post:

https://nypost.com/2019/09/01/cash-advance-app-earnin-changes-its-tune-amid-nys-probe/

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

Currently you have JavaScript disabled. In order to post comments, please make sure JavaScript and Cookies are enabled, and reload the page. Click here for instructions on how to enable JavaScript in your browser.

Previous post:

Next post:

The Houston Chronicle is dabbling in the in Payday and Title Loan conversation again

The Houston Chronicle is dabbling in the in Payday and Title Loan conversation again

by The CAB Man Texas on June 20, 2017

Babin, DiNardo: State should not loosen payday lender regulations. Written by Anna M. Babin and Cardinal Daniel DiNardo. 

Let’s take a minute and dice up this Houston Chronicle piece on Texas Credit Access Businesses.  The newspaper was apparently not satisfied with their role in passing the Houston “Payday Loan Ordinance” which caused a massive amount of closures in the City.  They still take up this reckless cause with Consumer Advocate and Church Groups by giving them a full and open forum to wage the war against the businesses that offer these loans and the people who need them.  The Ordinance raises payment amounts.  How does that help?  And the Chronicle looks the other way when this article’s authors say they do not want to put us out of business? Are they saying that with a straight face or with a wink and a smile?

So here is something new.  The 180-day limit on loans is something that Rep. Dan Flynn asked the Attorney General to look at, as it can be a limiting rule that restricts credit in a way that is unattractive to consumers.  The article stated that “At the close of the 85th Texas legislative session, an opinion request was submitted to the Attorney General to loosen restrictions in the Texas Finance Code for payday and auto title businesses that would allow for payment of loans to go beyond the 180-day limit that is clearly stated in the law.”  It went on to also say that “If the limit is lifted, payday and auto title lenders will only be required to guarantee that the arrangement of the loan is completed in 180 days, essentially expanding the length of the loan payback period indefinitely.”

Here comes the artful stroke of the brush: “Opening the door to longer-term loans would be a “devastating” blow to the hard-working, lower-income Texans who use these loans to cover basic needs, such as food, shelter and clothing.”  No.  Longer term loans mean more time to pay the loan back and lower payments.  More time to pay back means more flexibility and ability for the average borrower to manage their finances.  Lower payments mean more choices and less defaults.  How exactly is that going to be “devastating?” 

And then the qualifying disclaimer: “Our goal is not to put the payday and auto title lending industries out of business, but to ensure that reasonable regulations are in place to protect those most in need of the loans.”  (Ok, riiiiggghhht.  Grownups know better unfortunately.  These people want us out of business.

Here is the deal – Texas Credit Access Businesses have to fight and scrap every single day against people who are working to put us out of business via “thoughtful, meaningful, modest, additional restrictions.” It comes from all angles across the State and media outlets like the Houston Chronicle take up the cause without any word from our side whatsoever.  So, what happens?  41% of Credit Access Businesses in Texas close in a 4-year period.  There were 3,500 in 2013 now there are about 2,100.  With this 180-day rule, it is an issue for us that would help our CABs and customers.

Are the people who wrote and supported this article satisfied with the successful implementation of “thoughtful, meaningful, modest, additional restrictions” in the Payday Loan City Ordinance? No way – they still offer up their opinions on websites and newspapers and enjoy a wide-open forum to instill their false narrative.  These groups will not be satisfied until loans are free and that is no endorsement of the “American Way,” it is more Socialism than anything else.

This article was written and supported by people who want to shut us down.  And for some more fun, check out the hypocrisy below, the United Way accepted money from Texas Credit Access Businesses, $30,000 in fact.  Yet they are one of the groups we have seen bring on the hate speech at multiple City Ordinance hearings at City Council meetings across the State. I mean they really go for it – they HATE us and want others to think we are the devil reincarnated!

  • Anna Babin, President and CEO of the United Way of Greater Houston. (United Way accepted a $30,000 grant from Texas CABs! We can’t be all that bad, can we?)
  • Cardinal DiNardo is a Cardinal overseeing the Archdiocese of Galveston-Houston.
  • Stephen M. Fraga of Tejas Office Products Inc.
  • Irma Diaz-Gonzalez of E.T.C. Inc.
  • Lynne Liberato, chair of United Way THRIVE. (United Way accepted a $30,000 grant from Texas CABs! We can’t be all that bad, can we?)
  • Ping Sun of Yetter Coleman.
  • Dr. Steve Wells of South Main Baptist Church.

Here is the link to the press release about the $30,000 grants from Texas Credit Access Businesses to the United Way:

http://www.tfee.texas.gov/TFEE%20Grant%20Award%20Press%20Release.pdf 

Here is the link to the Houston Chronicle piece: 

http://www.houstonchronicle.com/opinion/outlook/article/Babin-DiNardo-State-should-not-loosen-payday-11209628.php

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

Currently you have JavaScript disabled. In order to post comments, please make sure JavaScript and Cookies are enabled, and reload the page. Click here for instructions on how to enable JavaScript in your browser.

Previous post:

Next post:

New Rules for Texas Credit Access Businesses

New Rules for Texas Credit Access Businesses

by The CAB Man Texas on October 23, 2015

The 2015 Texas legislative session passed a “Clean Up Bill”, which authorized the OCCC to review, repeal, and replace rules regulating CAB’s.  Those new changes were proposed in September for pre- comment and voted for approval by the Texas Finance Commission Board to be published in the Texas Register on October 16, 2015 (last Friday) at the Texas Finance Commission meeting in Austin, Texas.

We have counted approximately 144 new changes to TAC 7, Chapter 83, Subchapter B.  This is the first time in 4 years that any new rules for payday loan or auto title loan businesses known as “CABs” have been put into place.  It is time to get educated on changes and make the necessary modifications to your documents, processes, and other operating methods.

The changes affect a broad range areas from; Definitions; Licensing Fees, Notice of Delinquency of Annual Assessment, Denial, Suspension, Revocation based on Criminal History, Examinations, Files & Records, Separation Between Third Party Lender and CABs, and Case Hearing Procedures.

CAB Consulting has thoroughly reviewed the changes and put together a compliance plan to ensure CABs, their software providers, and third party lenders are compliant moving forward into 2016.   We are told the first round of changes are slated to be made effective in late December of this year or early January 2016.

If you would like to learn more, please contact Michael Brown at 214-293-8676 or Robert Wheeler at 956-639-7162.

Leave a Comment

Currently you have JavaScript disabled. In order to post comments, please make sure JavaScript and Cookies are enabled, and reload the page. Click here for instructions on how to enable JavaScript in your browser.

Previous post:

Next post:

City of Houston Passes Payday Loan Ordinance

City of Houston Passes Payday Loan Ordinance

by The CAB Man Texas on December 19, 2013

Yesterday the City of Houston passed a “payday loan ordinance.” The ordinance looks like the other ordinances in Dallas, Austin, San Antonio, and Austin.

The media and Houston City Council Members refer to the ordinance as Payday Loan or Payday Lending, but it also regulates Auto Title Loans, the term “Payday Loan” or “Payday Lending” is being used as an umbrella definition for the industry.

The Ordinance goes into effect on July 1, 2014. CAB Consulting and its clients have always been open to meaningful regulation of our industry. The same story has been told to the City Council by Consumer Advocate groups and the same boilerplate ordinance was passed. The 25% pay-down on principal is a major problem, the limit of 4 installments on multi-payment loans is a problem. Will likely cause an increase in defaults or increase in repossessed cars, something that neither Consumers or CABs want.

See below for the hi-lights on the Ordinance:

-CABs must register with Houston, cost $50.
-Registration Certificate must be displayed in plain sight.
-Certificates will be good for 1 year.
-Records must be kept for all transactions.
-Same basic records that are kept for Federal & OCCC Compliance will be required.
-OCCC Quarterly & Annual Reports must be kept on file.
-Records must be kept on file for 3 years.
-Cash advanced cannot exceed 20% of gross monthly income.
-Auto Title Loans may not exceed the lesser of: 3% of gross annual income, or 70% of the vehicle value.
-No more than (4) installments on multi-payment loans.
-Each refinance must include 25% payment towards the principal.
-No refinances on multi-payment loans.
-Single payment loans may not be refinanced more than 3 times.
-7 day cooling off period.
-Any new loan funded less than 7 days after a payoff is considered a refinance.
-Agreements must be written in customer’s language of preference.
-Every location must at least have agreements in English and Spanish.
-For every customer who cannot read, every agreement and disclosure must be read in its entirety to the customer in their language of preference.
-Forms with Referrals to Credit Counselors will be provided to Customers.

For more information, businesses affected by this Ordinance can contact the City of Houston Director of the Department of Administration and Regulatory Affairs.

Here is a link to the City of Houston “Payday Lending” Ordinance: Houston.Ordinance

Leave a Comment

Currently you have JavaScript disabled. In order to post comments, please make sure JavaScript and Cookies are enabled, and reload the page. Click here for instructions on how to enable JavaScript in your browser.

Previous post:

Next post:

Getting Dynamic in the Payday and Auto Title Loan Industry

Getting Dynamic in the Payday and Auto Title Loan Industry

by The CAB Man Texas on February 20, 2012

I know of many Credit Access Businesses in the payday loan and auto title loan industry who are getting “dynamic” with the way they are thinking. It seems like wherever I go it is the buzzword. New ideas are in play, and it is a pivotal time in our industry life cycle.

Legislative and regulatory drama is in the air as a result of the Consumer Financial Protection Bureau (“CFPB”) recently announcing their examination plans. They remain and unknown which causes fear in some, while others are inspired to conceive those new ideas that challenge established norms, tear down paradigms, and force an evolution into a new era.

Consumer need will not wane, it will continue to grow and become more sophisticated. So should your business!

What do you think “Dyanamic” means? Here are two definitions I like:

dy•nam•ic/dīˈnamik/
Adjective: Characterized by constant change, activity, or progress.

Noun: A force that stimulates change or progress within a system or process.

For many who have been in the business awhile, you know that one yellow pages ad is not going to secure your business the way it used to. Online operators who used to buy a lead for $20 and get a loan funded from a phone call and a bank statement know very well that was the “olden days.” Dynamic minds have since went to work and an evolution took place – the changes named above are only two of many.

What questions should you be asking today so that you can put your business on the track to long term success? Here’s a few to get you going… Have you embraced the reality that you need to evolve? Are you thinking about the needs of the customer? Are you looking at ways to improve vertical integration? Do you have a brand? What’s the competition doing? What’s the industry trend? Are you fully engaging the compliance process? Would you feel confident if the OCCC took you through and examination today? Is your software and reporting where it needs to be?

Michael Brown of CAB Consulting and Brokerage can be reached for questions and comments at 214-293-8676, or via email at cabconbrokerage@gmail.com.

Leave a Comment

Currently you have JavaScript disabled. In order to post comments, please make sure JavaScript and Cookies are enabled, and reload the page. Click here for instructions on how to enable JavaScript in your browser.

Previous post:

Next post:

Notices and Disclosures for use in Credit Access Business Operations

Notices and Disclosures for use in Credit Access Business Operations

by The CAB Man Texas on December 20, 2011

In addition to the provisional license, last Friday the OCCC worked to get rules for the Notices and Disclosures approved.  The rules, referred to as “7 TAC 83.6001-7 TAC 83.6008,” define the many ways in which a Credit Access Business is required to disclose particular information to consumers regarding the potential loan they are about to apply for, or for the actual loan that consumers agree to.

There are procedural requirements that a Credit Access Business address the nature of the transaction and possible alternatives to this service before the customer completes an application.   Also, the customer must acknowledge they have received these disclosures.

Considerable time has been invested in the development of several documents the OCCC advises Credit Access Businesses to use that are compliant with the law, and accomplish the goals of House Bill 2592.  Focus groups have reviewed the documents, and feedback was provided that shaped the final versions.  In the future it is likely that continued feedback from focus groups will shape these “dynamic” documents in a way that makes sense to all Credit Access Business consumers and stakeholders.

According to the OCCC, there is only one other state in the U.S. that has something similar or nearly as comprehensive.  The process of collaboration between the OCCC and industry stakeholders appears to have resulted in an exceptional set of detailed disclosures, which should please lawmakers and consumer advocate groups.   Fair regulations were passed, and rules were developed to implement the new State of Texas laws.  This high level State government achievement in should be made note of at the local level.  Knowing that such thorough systems are in place, city governments can now move on to more important topics like job creation and budget balancing.

The documents, which focus on single and multi-payment payday and title loans, are available through the OCCC website.  CAB Consulting and Brokerage is also in possession of the documents.  We are distributing them to clients, building familiarity with their intent, and drawing clarity from a 15 page two column set of rules.

If you have questions or would like to discuss, please contact CAB Consulting and Brokerage at 214-293-8676, or via email at cabconbrokerage@gmail.com

Leave a Comment

Currently you have JavaScript disabled. In order to post comments, please make sure JavaScript and Cookies are enabled, and reload the page. Click here for instructions on how to enable JavaScript in your browser.

Previous post:

Next post: