The online marketplace is booming and the brick & mortar store must adjust by increasing web presence and using alternative data.

The online marketplace is booming and the brick & mortar store must adjust by increasing web presence and using alternative data.

by The CAB Man Texas on April 9, 2019

We have been hearing a lot lately about the continued decline of retail business in the US.  Zales and Jared jewelry retail stores are the latest to announce closures of hundreds of locations.

Online is booming and it seems like Amazon rules the world.  If your business does not have an online presence you are missing out on a lot of opportunity because your pure brick & mortar market is shrinking by the minute.  Consumers are evolving and many low to middle income consumers are willing to do more and more to get access to credit at crucial times.  How will you engage with this new dynamic?

Forbes.com featured an article that discusses how increased online markets are opening a consumer’s willingness to share their personal info online while also touting the strengths of today’s alternative data.  I included some excerpts below.

“People Are Plenty Willing To Share Personal Data To Get A Better Loan.”

  • New research suggests that people are surprisingly comfortable sharing their data as long as it’s being put to good use, especially in the world of lending.
  • A recent Harris Poll found a surprising consensus among American adults — 71% of those surveyed said they would be willing to share more personal data with a lender if it led to a fairer loan decision.
  • More significantly, the Harris Poll shows that the majority of consumers feel unfairly treated by the current system.  More than 80% of African-Americans and Hispanics – and 7 in 10 of all adults – say they wish there were a better way to prove themselves to lenders.
  • But in today’s era of large-scale data collection and unlimited computing power, the traditional credit score is showing signs of age and mathematical limitations.
  • Consider some of the things credit scoring excludes: your job history, your roots in your town and thousands of other bits of information that are left untapped. It’s no wonder 70% of people polled say it’s difficult to get financial institutions to see them as anything but a number between 300 and 850.
  • One-third of renters say credit scores have kept them from buying a home.   
  • Alternative data simply means anything that’s not included in calculating a traditional credit score. It could include timely utility payments, history of holding down a job, even large debts you had years ago (outside of the traditional credit score models) that you successful paid off.
  • Bringing that added data into the credit scoring decision creates a more nuanced picture of borrower risk, helping banks spot worthy borrowers further down the credit spectrum (and flagging troublesome borrowers who look good on paper).
  •  The Omidyar Foundation found that in the six biggest emerging economies, using more data and machine learning techniques can get as many as 580 million unbanked people into the financial mainstream.”

Many of us are using “alternative data” with Factor Trust and Microbilt (often referred to as “Credit Reporting Agencies” or “CRA’s”).  If you are not, get on it as soon as possible!  

Factor Trust was recently acquired by Trans Union, and another CRA “Clarity Services” was acquired by Experian awhile back. In the future hopefully that will mean better things for how CRA’s are utilized by our industry and will also mean more robust access to credit for consumers.”

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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Can CSO-CAB’s Offer Multi-Payment Auto Title Loans for more than 180 days?

Can CSO-CAB’s Offer Multi-Payment Auto Title Loans for more than 180 days?

by The CAB Man Texas on April 12, 2012

A client of mine and I are seeking opinions on the 180 day limit on CAB multi-payment auto title loans Per Texas Finance Code Chapter 393.201 (Form and Terms of Contract) and Chapter 393.001 (3).

Chapter 393.201 states that a credit service contract is between a CSO-CAB and a consumer, and that the services to be performed under that contract listed under 393.001 (3) must be completed within 180 days.  Many operators interpret this rule simply, and say “this means we can’t participate in multi-payment loans for more than 180 days.”

But, my client is thinking that the promissory note component of the contracts is between the Third Party Lender and the consumer, is not related to the rules just cited, and so 393.201 should not apply.

Why?  The client’s CSO-CAB services to the customer are almost all completed on day 1 of the loan.  After that such services as taking payments on the loan, forwarding the payments to the lender, and guaranteeing the loan, are services provided by the CSO-CAB to the lender, and not the consumer.  So, again 393.201 should not apply because these are not the service listed under 393.001 (3).  The service of assisting and obtaining loans for the consumer as per the credit service contract are done well within the 180 days.

#1 priority for client is to abide by the rule of the law…please provide your comments on this we are seeking OCCC and industry opinion.

There are many benefits to my client and the consumer for loan programs that are beyond 180 days.  Let’s dig a little on this.

As always, check in with Michael Brown via email at cabconbrokerage@gmail.com or call 214-293-8676.

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Credit Access Business rules for 2017 that you need to know!

Credit Access Business rules for 2017 that you need to know!

by The CAB Man Texas on January 13, 2017

New Technical Rules for 2017 you should be aware of.  Did you know there are new rules related to the application for new licenses, transferring a license, and criminal history of CAB owners?  Much of this was covered during CAB Consulting’s “CAB II” project that many clients and members took advantage of. 

*The language for rules and transfers removes the part mentioning that you need to wait on the OCCC’s approval to operate a CAB while the license is being transferred. The transformer assumes all responsibility of the license until the license has been transferred to the transferee. 

**Criminal History can affect license holders. This affects anyone with a State license from a concealed handgun license to a Credit Access Business license. In the eyes of Texas, it is a privilege to maintain a Texas license, and therefore license holders must be law abiding residents.  

Here are several areas of infraction that could compromise your CAB: 

Theft, assault, any offense that involves misrepresentation, deceptive practices or making false or misleading statements. 

Any offense that involves breach of trust or other fiduciary duty.

Any criminal violation of a statute governing credit transactions or debt collection. 

Failure to file a government report, filing a false report or tampering with a government record. 

Here is a link to the rules: http://occc.texas.gov/sites/default/files/uploads/pub/rules/cab-adoption-fc-010517.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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The United States Postal Service as a Financial Services Provider

The United States Postal Service as a Financial Services Provider

by The CAB Man Texas on February 12, 2014

So the United State Postal Service might become a financial services provider? I have been hearing about this over the last couple weeks, and am I missing something here? Perhaps I don’t have all the facts, but is this really being considered as a possibility by our Federal government?

I think that the Post Office offering financial services such as bill payment, debit cards, and savings accounts could theoretically be possible. Has anyone been to a Post Office recently? How could they manage to add on such high touch, data sensitive, disclosure heavy, non-traditional services? The Post Office loses billions of dollars every year, it is antiquated, archaic, and lost in the past. How would these new services be launched, managed, and made profitable? The most important question regarding anything to do with the Postal Service is: could it ever be profitable? If not, then what is the point? These are crucial points that any successful business person would make, so how about the media publishes some comments from business people on the matter? Consumer Advocate groups dominate the public forum with strong media support, but the problem with that is their groups typically aren’t saddled with the need to turn a profit!

Post Office lines are long and slow, the offices are understaffed, and the average Postal worker I encounter when I go to a local office doesn’t exactly come off as pleased to serve me. There is a systemic dysfunction within the Postal Service that could be a very large road block to the addition of financial services to its existing workload. Will the government hire more people to work there to handle the larger workload? Will the government pile more payroll expense onto an entity that loses something like $10 billion per year? I haven’t really seen anyone else make that point in the media – and I haven’t even gotten into the topic of small dollar loans yet.

Here are some more questions that must be asked… Is the government going to lend consumers money? Who will provide the funds for the short term loans? Is a government agency that loses $10 billion per year now going to fund small dollar loans to consumers in need of emergency credit? What interest percentages are they going to charge? One more thing: it is very easy to fund a loan – who is going to collect on the loan? 99% of the loan business is collecting! Is the United States Post Office going to also be a “Collections Agency?”

The Post Office’s record and profitability make it the absolute worst candidate for loaning consumers money, they would lose millions in taxpayer dollars, guaranteed. This is another important point that Consumer Advocates never consider – consumers often do not pay back loans at all, and many consumers must be consistently communicated with to keep from defaulting. People make jokes about the government giving money away, well this program would certainly end up as some of the easiest money ever.

Consumer Advocate groups are opponents of my clients and it is my opinion that these groups want to see all of us out of business, despite my being told otherwise. It is also my opinion that Consumer Advocate groups will never be satisfied until loans are made at 0%, despite my being told otherwise. Now these groups tout the Postal Service as the next in line to fight against predatory lenders in the “Payday Loan” industry.

So, when the Post Office funds loans to consumers at 36% APR are the Consumer Advocates going to go after the government for taking advantage of the very citizens it is there to serve? Problem is, the Post Office is going to have to charge more like 500% APR to be profitable, and don’t forget that will only put them in position to be profitable. What if they do a really horrible job? It could get really bad.

I have to say that I do not want a single penny of our country’s tax dollars going towards the Post Office offering financial services. I am sure millions of people feel the same way. This would be an absolute nuclear bomb of a loss, so many people would be fired and resign over this idea that it would go down in history as one of the most epic failures on record.

I would love to hear your comments on this, and would be thrilled to see any of these comments get picked up in the media. Submit a comment or reach out to me as always at 214-293-8676 or via email at Michael@CreditAccessBusiness.com.

{ 1 comment… read it below or add one }

Jer – Trihouse February 12, 2014 at 11:50 pm

Michael,

Insightful commentary! I can’t imagine taxpayers funding these loans! Worse, the banks are going to “partner” with the United States Postal Service? The ultimate “loan sharks.”

Add to this equation the collection call center personnel working out of India! “Hi, my name is Bobby and you’re going to prison if you don’t pay my client, the United States Post Office, their MONEY! (WOW! Great Blog Post idea!)

In order to pull this off, the FED’s would have to provide clarity and federal direction regarding the 50 states. Why not do this now and allow entrepreneurs to figure out how to construct an appealing product and compete with one another? Why should taxpayers, the FED’s, the U.S. Post Office and banks collaborate and compete against private business?

Next, the FED’s, in conjunction with consumer literacy groups, will decide the American reading level is not what it should be and launch a new enterprise to compete against Amazon.

Reply

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OCCC looking for engagement with Texas Payday Loan and Title Loan CAB’s

OCCC looking for engagement with Texas Payday Loan and Title Loan CAB’s

by The CAB Man Texas on February 13, 2012

Attended last week’s OCCC meeting in Austin and saw stakeholders from a multitude of industries speak up with opinions, questions, etc.  The OCCC had arranged the meeting with the goals of getting feedback from stakeholders in several regulatory areas on where they see their industries now, where they are headed in the future, and how the OCCC is doing.  An open forum was given for stakeholders to speak up, ask questions, and offer opinions…

From the meeting I took away that the OCCC is focusing on:

-Customer Education
-Outreach
-Engagement
-Financial Education
-Increase Online Activity
-Advise businesses to look at existing regulations, not just the new regulations
-Urge businesses to participate in dialogues with OCCC
-Re-iterated that stakeholder input in Texas is unique, not seen in many other states

In the meeting there were many who spoke up, but not what I would call a flood of questions and comments.  The OCCC is really making an effort to ask for industry feedback – take advantage.   The squeakiest wheel gets oiled first!

Questions you would like asked?  Let me know I will send them in on your behalf.    As always I am pleased to take your calls on all matters CAB, and if you want to learn more about the OCCC areas of focus cited above don’t hesitate to call Michael at CAB Consulting and Brokerage at 214-293-8676, or email cabconbrokerage@gmail.com

 

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Payday Boot Camps offered by CAB Consulting at Partner store location in Austin, Texas

Payday Boot Camps offered by CAB Consulting at Partner store location in Austin, Texas

by The CAB Man Texas on June 15, 2017

CAB Consulting has partnered with Star of Texas Financial Solutions in the Austin, Texas area to offer live in-store training sessions to start ups wanting wide and narrow scope guidance on how to get going with their payday, installment, or auto title loan venture.  As well, Payday Boot Camps are often conducted for existing companies wishing to elevate their business to another level by implementing the leading edge operating techniques we demonstrate while in our “live” storefront, or who wish to add additional products or services.

The two-day sessions are comprised of conversation and instruction in the conference room, as well as “behind the counter” demonstrations of actual transactions in the loan management system with real customers right there in front of you.

In years past, CAB Consulting has conducted Payday Boot Camps with Tri-House Consulting in California (THANK YOU JER!), and in 2016 we began hosting them in Texas at Star of Texas Financial Solutions in Austin.  This has been an extremely valuable tool for individuals considering an entry into the “payday” industry.

In the two-day sessions we cover payday loans, installments loans, and auto title loans.  We have hosted groups mostly from States in the U.S. like Texas, Utah, and Nevada.  As well, we have conducted sessions for companies from Canada and South Africa.

No matter what State or Nation we have been able to deliver expertise on industry basics as well as licensing and regulation.  CAB Consulting clients will be advised on best practices, vendor selection, underwriting, third-party lenders (Texas and Ohio), and much more.  We are a comprehensive consulting business with specialties in multiple states that can deliver 100% of what is needed to start a payday business, to run one, and to make a profit.

Our industry has experienced a marked resurgence with the recent governmental changes, and CAB Consulting has seen a major uptick in Payday Boot Camp interest.  We are ready to go when you are!

If you would like to learn more about our Payday Boot Camps, call or email to contact Michael Brown, let’s review the program details together, and set a date!

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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Let’s get prepared for an OCCC Examination!

Let’s get prepared for an OCCC Examination!

by The CAB Man Texas on July 29, 2013

CAB Consulting has been helping small and mid-size Texas Credit Access Businesses navigate the new CAB licensing model ever since its passage just over 2 years ago. Having served almost 200 locations during that time, CAB Consulting could be a great resource for your company. Does your business need a compliance review? Do you feel your business is prepared for an OCCC examiner to walk in your door?

Audit Alert: OCCC examiners are actively traveling the State right now and they typically show up at your door un-announced. Several clients have been examined this month. CAB Consulting clients will be fully prepared for an examination and will know exactly what to expect.

What other needs might your business currently have? The principal of CAB Consulting, Michael Brown, would like to work with you on your Payday or Auto Title loan store to make operating improvements, increase compliance, grow confidently, and become more profitable.

CAB Consulting can deliver a wide array of results to your business, call 214-293-8676 today to learn more, or visit www.CreditAccessBusiness.com for information!

{ 2 comments… read them below or add one }

ft August 10, 2013 at 7:31 am

Michael, the auditors showed up today! Our contracts are a mess, we overcharge on the lender fees, the APR’s are wrong… wish I’d have listened to you and have your team audit my stores first :o(

Reply

Anonymous August 10, 2013 at 7:35 am

Hate to see it happen to you, FT. Hopefully the set backs aren’t catastrophic. Let’s schedule a intervention the following week.
Michael

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Many more Americans need access to alternative loan or “payday” services than you may think, this is who they are…

Many more Americans need access to alternative loan or “payday” services than you may think, this is who they are…

by The CAB Man Texas on December 17, 2016

Did you know?

  • 7 in 10 Americans have less than $1,000 in savings in case of emergency.
  • 34% of Americans have zero savings.
  • 5% of Americans have relied on payday loans or similar services.

Customer Demographics – per a Georgetown University McDonough School of Business study:

  • Majority earn between $25,000 and $50,000.
  • 90 % have a high school diploma or better, 54 % have some college or degree.
  • 53 % are under 45 years old (only 9 % are 65 or older).
  • Majority of customers are married and 63 % have children in household
  • 32 % own homes, 54 % have credit cards, 100 % have steady incomes, 100 % have checking accounts.

For more information, go to:  http://cfsaa.com/about-the-payday-advance-industry/customer-demographics.aspx

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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Texas CAB Credit Access Business Solutions

Transition & Training Pckg

The Transition and Training package is a comprehensive program that includes all of the items from the CAB Packet but goes many steps further with its commitment to taking your company from a non-licensed CSO to a fully licensed and compliant CAB in just a few months. C.A.B. Consulting and Brokerage will work directly with ownership or designated team leaders to make sure the steps towards license approval are taken, that your teams are educated with proper information, and that your operation is compliant with OCCC regulations. Because C.A.B Consulting and Brokerage works with its own attorney, who is experienced in the payday loan industry, we can offer this package to you with all of its elements at a lesser cost than completing the process internally.

Summary of included items and services:

Service:

•Collaboration with Texas CSO owners or designated employees to manage the complete licensing process
•Continued management to file quarterly transaction reports beginning April 2012
•Owners, managers, and employees attend a 1-hour online training course
•Mystery Shopping option offered twice per month completed by experienced consultants
•Provide your business with the C.A.B. Consulting and Brokerage “Certificate of Completion”

Documents:

•Neatly organized task checklist
•O.C.C.C. authenticated, verified, and approved
•Fee Schedules for use on documents, web-sites, and at retail locations
•Disclosure form templates with instructions
•Provide template documents for use in license application
•State of Texas Credit Access Business application with instructions
•Loan documents for consummation loans
•Bonds

Resources:

•Reference copies of important laws and regulatory publications
•A summary letter of transition process and final copy of OCCC Credit Access Business rules
•Add your company employees, managers, and ownership to our company Newsletters, Emails, RSS Feeds so that we can continue to educate your organization when needed, help your teams stay abreast of developments, and share with you opportunities that may benefit your organization

To learn more about details and specifics of this package, contact C.A.B Consulting and Brokerage at cabconbrokerage@gmail.com or call 214-293-8676.

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