For the benefit of those who read our posts we are sharing a snapshot on the progress of a five-location retail chain’s Search Engine Marketing Campaign after six months.  This particular business offers cash advances and title loans in the Central Texas area.  What do you think?  Is it doing well with SEO? Room for improvement?  How about your title loan or cash advance business?  Is it doing better or worse?  

The results shared here are what will net a business 148 online applications in one month which was the actual April 2019 total.  It could and probably will be higher in future months because this time of year traditionally is the lowest in demand.  That being said, right now this cash advance and title loan business is achieving some of its best results since starting the SEO campaign in late September 2018. 

The SEO team at Hearst Media Services, 
https://hearstdms.com/localedge/tofsc (contact Ahmed Khalaf and team!) is handling this campaign and provides monthly reports that summarize where the business is at in a number of ways, what changes are made by them for you to improve, etc. 

Statistics that were reported for April:

·         43,000 impressions.

·         588 clicks.

·         148 online applications.

·         Online traffic has increased 20% since starting the SEO campaign in September 2018.

·         Cost broke out to $6.35 per lead generated.

What are the top sources of traffic?

70% Google, 20% is from actual entry of the website address, 2% Yelp, 2% Facebook, the rest was “others.” 

Comment: No surprises there, Google is king, and everyone needs to max out on this search engine every way they can! Yelp is proving to be a good source too, check them out directly.

What pages are visitors entering on?

Home, then contact us, across the board. Big drop off after that. 

Comment: This tells us site visitors check out the business online, get a feel for it, then look for a phone # to call and get a live person.

What cities are generating organic traffic?

Top 10: Austin, Dallas, Abilene, Houston, San Antonio, Waco, Round Rock, Pflugerville, New Braunfels, San Marcos. 

Comment: Strange to see Dallas and Houston pop up in these stats as the business is not located in those cities.

What search terms are leading customers to the website?

Top 10: Title loans, car title loans, Star of Texas, Title loan, Car title loan, Star loans, Auto title loans, Installment loans company, Installment loans Texas, Title loan near me.

Comment: Surprised that cash advances was not at least half of the top six results here. Not understanding why title loans was so popular.  Is the website more optimized to title loans versus cash advances?

For more information on the topic of SEO for your cash advance, payday loan, or title loan business, feel free to reach out to Michael Brown at the contact below, and to get in direct contact with the real experts call Ahmed Khalaf at 716-541-4174, or email him at akhalaf@hearst.com.

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.

Pretty big news coming from CFPB and Cash America today, $19 million in refunds and fines laid down on Cash America. $5 million of the $19 million is penalty and the remainder will be refunds of fees paid by consumers.

Cash America apparently violated some debt collection rules and also had some improper internal behavior where they were attempting to hide information from CFPB. I believe most of the activity occurred in Ohio.

This is the first major action by the CFPB and a number of papers across the United States are featuring the story. I would recommend that we all stay on top of the CFPB topic. I watch them out of the corner of my eye and know it could be a major concern in the future.

Here’s a link to the article on the front page of The Dallas Morning News: http://www.dallasnews.com/

Although we are all hopeful the proposed CFPB rule will unravel in the near future, the CFPB action against Moneytree is a good reminder that we can at any time be examined by the CFPB in the same way that the OCCC can show up at our stores at any time.

Specific to this particular action was collections and advertising.  The information on www.CFPB.gov stated that there were “deceptive online advertisements and collections letters.” And that “the company also made unauthorized electronic transfers from consumers’ bank accounts.”

CFPB has ordered the company to cease its illegal conduct, provide $255,000 in refunds to consumers, and pay a civil penalty of $250,000.

What did the CFPB say Moneytree did wrong?

§  “Used deceptive online ads: In early 2015, Moneytree ran advertisements online offering to cash consumers’ tax refund checks for “1.99.” The actual fee for the service was 1.99 percent of the amount of the check cashed, rather than $1.99, as the company’s advertisements implied. Consumers were required to visit one of Moneytree’s physical branches to take advantage of the advertisement’s offer, which appeared online tens of thousands of times.”

§  “Deceptively told consumers their vehicles could be repossessed: From late 2014 through early 2015, Moneytree mailed letters to hundreds of consumers indicating that their vehicles could be repossessed if they did not make past-due payments on their installment loans. But none of these consumers had loans secured by their vehicles, and Moneytree had no right or ability to repossess them.”

§  “Withdrew money from consumers’ accounts without authorization: Moneytree failed, in over 700 instances, to obtain pre-authorization from consumers for withdrawals from their bank accounts, in violation of federal law.”

What are the take-aways?

Advertising:  As an owner of your business ALWAYS read the final proof of all advertising and distribute the policy on a campaign in writing to your team, communicate the policy verbally as well so that emphasis can be made in areas where necessary.   Think critically about how a statement can be interpreted on your advertising materials, ask yourself “If a regulator who wants me out of business reviews this how else could this advertising copy be interpreted to be accurate or to be misleading?”

Collections:   I am not sure if this was an error or if it was intentional that Moneytree sent letters to debtors saying they were going to repossess their vehicles if they did not pay their unsecured loan off.  I am going to assume that this was an error I really have not met anyone in the last (5) years of consulting that would do that kind of thing intentionally.  As an owner of your business make sure to review and approve collections letters as they go out.  Collections (and in particular repossession) is a risk laden mine field on the regulatory front.  There are too many instances of fines occurring due to internal error in Collections not to make sure you keep an extra close eye on this crucial part of every business.

ACH or Debit Card authorizations: Everyone must get an ACH or debit authorization for every transaction.  Only debit the amount(s) due per the agreement and payment amounts must match what is on the payment schedule.  Most know this, but often times the employees get bogged down or too busy and these errors occur.  An automated e-sign process helps this as signature lines are less likely to get missed.  If you do not have the authorization signed, it could be deemed “illegal.”

Link to story: http://www.consumerfinance.gov/about-us/newsroom/cfpb-takes-action-against-moneytree-deceptive-advertising-and-collection-practices/

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.

Some very positive news came out of Lubbock with the City Council voting down the “Payday Loan Ordinance” by a vote 5 to 2.  Credit Access Business owners all across Texas were impressed by Lubbock’s push back of the liberal backed City Ordinance.  Ordinances across Texas have shut down over 40% of Credit Access Businesses in the last several years.  

Rates have increased as CABs have fought to survive the ordinances, access to credit for consumers who need it most has decreased.  The ordinance issue just another reminder that liberals meddling with small businesses and the passage of more regulation ends up hurting the consumer they say they are trying to protect.  

We have quite a lengthy set of rules and regulations that govern Credit Access Businesses in Texas.  And, the Office of Consumer Credit Commissioner does an effective job at overseeing Credit Access Businesses.  Let the conversation about “payday” stay at the Capitol and trust in the statewide legislative process.

If you already are one, or if you are laying the groundwork for becoming a Credit Access Business in Texas, consider cementing your Third Party Lender component with more than a handshake.  It goes without saying that we need to invest in proper consumer loan documentation and operating software.  We should also do the same with our approach to the Third Party Lender relationship.

Now that the OCCC is closely examining many facets of the CAB as it operates, it is critical that you have a clear arrangement between your business and the Third Party Lender who issues loans through your CAB location.

Do you know that many CAB’s have written contracts which serve as the operating policy between them and the Third Party Lender?  It is important that the CAB invests in this written company policy, and that it can be produced upon request.  Do what you can to have a well rounded agreement in place as means to demonstrate your commitment to operating lawfully and fairly.  Gain confidence in your readiness for an OCCC examination.  Operating reports that echo your Third Party Lender Agreement are an intelligent addition to a well designed arrangement.  CAB Consulting and Brokerage is working with licensed Credit Access Businesses and Third Party Lenders in Texas in these matters.

We can assist you in a review and improvement of your Third Party Lender arrangement.  Feel free to contact Michael Brown at CAB Consulting and Brokerage at 214-293-8676 or cabconbrokerage@gmail.com to learn more.

This bill was written by Rodriguez. It is the opinion of CAB Consulting that this bill addresses Credit Access Businesses operators who were allegedly providing services without holding a post check, or without a vehicle title. The operators in question may have intentionally forfeited their CAB licenses and just operated as a CSO’s, which was a method employed to adapt to local ordinances. Local ordinances were put into place to regulate and restrict “Credit Access Businesses,” not “CSO’s” who weren’t holding post-dated checks or filing liens on auto title loans they brokered. The bill makes revisions to existing rules and statutes, and edits-down the definitions of key terms like deferred presentment and motor vehicle title loans. By doing so the bill would theoretically prohibit operators (CSO’s and/or CAB’s) from this continuing this practice. Simply put, simplifying the definitions and rules gives the law broader applicability.

The OCCC issued an advisory bulletin on this subject recently and noted that the legislature would likely look into this matter. HB 786 also gets into some requirements about CAB contracts, they would need to say “no prepayment penalty”, must “comply with FDCPA,” “may not threaten or pursue criminal action,” must comply with Military Lending Act, 10 USC 987,” etc. Also, the third party lender must be disclosed, along with their interest charged, the CAB fees charged, etc.

There are some revisions to the Texas Finance Code Chapter 393.221 definitions, lines are drawn through certain phrases within the definitions on deferred presentment and auto title loans. Appears to address the work arounds mentioned above. The bill goes on to require CSO’s to get a CAB license if they are going to perform services detailed & defined in this bill under the modified definitions. Additional attention is given to other issues on disclosures and reporting, no new topics there.

Click here for House Bill 786! HB.786