Cab Manual

Cab Manual

The CAB Manual contains the basic information needed to start the licensing and compliance transition process. Ordering this manual from C.A.B. Consulting and Brokerage will assemble all necessary elements to begin the transition process, eliminating the need to go to more than one place for initial information, guidance, and paperwork. The manual materials are offered in print and online for our client’s reference when needed.

Summary of included items:

•Transition process summary and opinion letter with important information related to the new license and licensing process
•Compliance summary and opinion letter with important information related to notices and disclosures
•Reference copies of important laws and regulatory publications
•Rules summary with interpretation and comments
•License application documents
•Inclusion of company members to the CAB Consulting and Brokerage Newsletters, Emails, and RSS Feeds

C.A.B Consulting and Brokerage does advise clients who purchase this manual that further research will be necessary and seeking the consultation of an attorney who specializes in the payday loan industry is recommended.

To learn more about details and specifics of the CAB Manual, contact C.A.B Consulting and Brokerage at Michael@CreditAccessBusiness.com or call 214.293.8676.

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What is a FinTech really? Be one.

What is a FinTech really? Be one.

by The CAB Man Texas on October 7, 2019

Seems like over the last year that the industry buzzword has been “FinTech.”  According to BuiltIn.com “”Fintech” is a portmanteau (combination of two words to create a new one) of financial” and “technology.”  It is the application of new technological advancements to products and services in the financial industry.”

For those of us in business in Texas, “FinTech” is a term that is slowly evolving away from a vague Silcon Valley-esque concept to something that is becoming more clear and accessible by the week.  It seems like that with the conclusion of the Lend360 Conference last week in Dallas that the buzz around the term hit an all time high.  A few weeks ago I shared summary details about the upcoming event, talked about some of the topics, sessions, etc.  Turns out that it was heavily FinTech oriented for sure.  Many of my “google alerts” lit up with FinTech stories and articles after the Conference and it turns out that many friends of CAB Consulting and TOFSC attended as well.  

On September 26th one particular article on Banking Dive.com really hit home and painted a very clear picture of what FinTech is and how it is playing out in the personal loan marketplace.  The article was titled “FinTech leaders have doubled their market share in 4 years” that commented on a recent study done by Experian.  See below for some of the more interesting comments and findings:

  • Fintechs are providing 49.4% of unsecured personal loans as of March, according to a study released Tuesday by credit reporting agency Experian, more than twice the 22.4% share they held in 2015.
  • In 2019 there were 1.3 million new loan originations through March, compared with 656,000 through March in 2015.
  • The loans are getting smaller…the average fintech loan was $5,548 in 2019, less than half the average amount of a fintech loan in 2016, when it was nearly $12,000.
  • The loans are also smaller than the $7,383 traditional bank loan averaging.  (Comment: It is very possible that the average was driven down by smaller loan amounts in our CAB sector and in other payday loan State markets…for example we know that 26 out of State CABs (most of which are FinTechs) now own 50% of the entire Texas CAB installment loan market per the OCCC Q2 2019 reports, with an average loan amount of $740.  This is really astounding as it seemed like very recently this was 1/3).
  • Customers may be increasingly relying on fintechs because they’re able to approve and fund a loan more quickly than traditional lenders or perhaps because, with a digital lender, borrowers don’t have to leave their house.
  • Fintechs were quicker to recognize that consumer lending niche and improve the customer experience with pre-approvals and quicker funding of the loans.
  • We’re seeing fintechs create digitally streamlined, customer-focused experiences, which may be the key contributor to their substantial growth in the personal lending space,” “Fintechs may be gaining traction as they are eliminating potential barriers consumers may face and are creating a more convenient experience.”
  • Millennial consumers (age 20-37) accounted for 34.9% of fintech loans, compared with 24.9% for traditional lenders.
  • Baby boomers (AGE 55-73) accounted for 33.5% of traditional loans, compared with 21.9% for fintechs.”

Here is a link to the article: https://www.bankingdive.com/news/fintech-lenders-double-market-share-in-4-years-experian/563793/

There should be plenty of inspiration here for the forward thinking Texas CAB that is operating in the brick & mortar environment.  How can brick & mortar stores emulate a FinTech?  Of the techniques employed by FinTechs we can do much of the same see below for how you can take one step closer to being a FinTech too by “adding new technological advancements to your products and services.”

  • How can you fund loans remotely because borrowers don’t want to leave their house? Do ACH credits and also debit the customer payments from their bank account.
  • Do you have e-signature capability? Have customers sign their documents online without coming into your store (also opens up your market to borrowers who would not come in due to privacy concerns).  
  • How can you increase processing speed to fund loans quicker? Smart phone app! Send texting with links! Prompt calls from your team to guide the process. What barriers slow your process down?
  • What does your website look like? Have it designed professionally and use FinTechs as a creative example fr the look and feel.
  • Search Engine Optimization. Are you investing in this every month? Do it.
  • Utilize data from Credit Reporting Agencies that allow decision making within seconds.  If you are not with Factor Trust and Microbilt this is them, sign up!
  • Access banking activity with instant bank verification tools from Decision Logic and Microbilt.

So there you have it…a road map to becoming a small business FinTech without all that Silicon Valley capital raising and no high dollar public relations firm.  From my perspective we are really all just that close.  The numbers do not lie and as said earlier, the picture is very clear.  The lending market has evolved and if your business has got to evolve too.  

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 “Lend 360” Conference is coming up in Dallas on the 25th here are the summary details.

The “Lend 360” Conference is coming up in Dallas on the 25th here are the summary details.

by The CAB Man Texas on September 24, 2019

The “Lend 360” Conference is coming up in Dallas, September 25-27.  Since it is in our back yard versus Florida or California wanted to discuss it a bit and give you some information for you to better decide on whether you will or will not attend. 

Many of our vendor and TOFSC sponsor companies will be there so that is a great reason to go out of the gate. (Microbilt, Clarity, Leads Market, Factor Trust Trans Union, Dot 818, Payliance, Repay, Zero Parallel, Infinity, and Loan Payment Pro) along with many others.

Looking at the schedule over the 3-day period…it starts at 1p on Wednesday, goes until 5p. Thursday is 8a-5p, and Friday is 8a-1130a.  The format appears to be traditional conference presentation style, in 8-10 different rooms of the Fairmont Hotel in downtown Dallas along with a larger vendor / sponsor booth gathering area.

Summary of presentation topics:

  • Federal law – conversation around lending.
  • Small business customer acquisition (could be very relevant to our group).
  • All parts and pieces of the “FinTech” industry – this is the major component of the conference.
  • 2020 election impact on FinTech.
  • Investor outlook on Fintech.
  • Conversation on moving into “alternative credit market” and products / services in the “non-prime market.
  • How FinTechs work with banks, there is more than one of these, so it appears to be a big part of FinTech operations…interesting.
  • How to use multiple domain names for your business online to drive traffic to your business (could be very relevant to our group).
  • Staying ahead of fraudsters (could be very relevant to our group).
  • Data security.
  • FinTech investors and other capital providers will be in attendance and will speak.
  • Advertising and marketing round table (could be very relevant to our group).
  • Making your business recession proof.
  • Optimizing debt selling and collections strategies.

Costs $2,600 to attend and here is a link to more information:  https://www.lend360.org/schedule/

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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OCCC is having a special stakeholder meeting on the questions posed to the Attorney General recently about CSO’s.

OCCC is having a special stakeholder meeting on the questions posed to the Attorney General recently about CSO’s.

by The CAB Man Texas on December 3, 2019

See below for a recent email sent out to OCCC stakeholders:

“On December 9, 2019, at 2:30 p.m., the OCCC will hold a stakeholder meeting on credit services organizations and attorney general opinion KP-0277.

A stakeholder meeting notice is available at: https://occc.texas.gov/publications/attorney-general-opinions. On this webpage, click the link labeled “Stakeholder Meeting Notice.” The meeting notice provides additional details and questions on which the OCCC is seeking input.

Stakeholders are invited to attend the meeting in person at the Finance Commission Building, or to listen and participate through an online webinar. To listen or participate online, please follow the instructions available at: https://attendee.gotowebinar.com/register/3659168503230489611

The OCCC will accept comments and suggestions on the questions in the meeting notice until December 12, 2019, at 5:00 p.m.”

OCCC is asking stakeholders for comments and suggestions on the topics below:

1. Does the opinion’s analysis affect the regulatory landscape for CAB transactions (i.e., deferred presentment transactions and motor vehicle title loans)?

2. Must persons engaged in non-CAB transactions comply with all requirements of Chapter 393 other than those that apply specifically to CABs (i.e., Section 393.201(c), Subchapter C-1, Subchapter G)?

3. Are persons engaged in non-CAB transactions subject to the enforcement authority of the attorney general under Section 393.502?

4. Are persons engaged in non-CAB transactions subject to local ordinances and the enforcement authority of local governments?

5. Are persons engaged in non-CAB transactions subject to federal law and the enforcement authority of federal agencies (e.g., the Consumer Financial Protection Bureau, the Federal Trade Commission)?

6. Sections 14.101 and 14.201 of the Texas Finance Code give the OCCC authority to investigate and enforce violations of Chapter 393 with respect to a credit access business. What is the proper role of the OCCC in light of the opinion?

7. Section 393.602 of the Texas Finance Code says a person may not use a device, subterfuge, or pretense to evade the application of Chapter 393, Subchapter G. Under the opinion, what would constitute a device, subterfuge, or pretense to evade the application of Chapter 393, Subchapter G?

8. Section 393.303 of the Texas Finance Code says a credit services organization may not charge or receive from a consumer valuable consideration solely for referring the consumer to a retail seller who will or may extend to the consumer credit that is substantially the same as that available to the public. Under the AG opinion, what would constitute a violation of Section 393.303?

9. Does the opinion’s analysis raise other significant policy issues? 

10. Should the OCCC and the Finance Commission engage in rulemaking related to any of these issues? If so, what is the statutory basis for the rulemaking?

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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CSO-Old Way

CSO-Old Way

The Credit Services Organization (CSO) model is the business model that payday loan companies operate under in the State of Texas.

The CSO is defined by the Texas Credit Services Organization Act and Section 393 of the Texas Finance Code. The code defines a CSO as an entity that provides services that improve a consumer’s credit rating, obtain an extension of credit for the consumer, or provides assistance to a consumer regarding credit improvement or extensions of credit.

In reality, all payday lenders in Texas are not true payday lenders.  They do not sell a traditional payday loan compared to other states, and, in contrast, they call themselves CSO’s. In Texas, a registration certificate is required and allows payday loan businesses to act, more specifically, as brokers who arrange for a consumer to receive a loan from a particular Third Party.

The customer pays fees to the CSO for arranging the loan in an amount typical to the industry, $20 per $100 for example.  On the contrary, there is no limit to what can be charged by the CSO. The Third Party, called the lender, issues the money to the consumer and is paid interest for that loan of usually just under 10 percent APR.

Why do all companies in the payday loan business in Texas operate under this model? After this creative business model launched it quickly landed in court as Lovick v. Rite Money. The case was heard in the U.S. Fifth Circuit Court of Appeals, where an opinion was issued, which held that payments made to the CSO were not to be considered interest. The model was deemed viable, and once word spread about the ruling and the viability of the CSO model, companies began adopting it and expanding rapidly.

Lending was easy under the CSO model when all that was needed was a registration certificate and a Third Party lender to sell loans. After the new laws, House Bills 2592 and 2594, were passed in 2011, adopted regulations changed the payday loan business. Now called the Credit Access Business (CAB), payday loan businesses are required to have a new license, pay more fees, and operate in compliance with a new set of required notices, and disclosures.

The new laws go into effect on January 1, 2012. At that time, CSO’s must have their CAB license in place alongside the new required consumer notices and disclosures in order to be compliant.

C.A.B. Consulting and Brokerage — Texas Credit Access Business Resources — Page 2

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

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 […]

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Back to School is here is your small business ready?

August 13, 2019

Did you know that for many the Back to School season each August is the second highest seasonal demand period for the payday industry?  Only the Christmas and New Year Holiday time frame beats Back to School in terms of seasonal demand. For Texas Credit Access Businesses offering cash advances, payday loans, or title loans, […]

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A new tool for payday borrowers that may or may not be a good thing for loan defaults.

August 6, 2019

Recently another new dynamic in our industry has surfaced and this is reminder that as a small business owner in the payday loan-cash advance-installment loan industry, everyone on your team needs to continually study and learn customer behaviors.  What is this new dynamic? It is the borrower habit of switching their debit card “on” “off” […]

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Retail “brick and mortar” businesses across many industries continue to shutter. Why?

July 29, 2019

In today’s world of the smart phone, apps, and Amazon, every retail “brick and mortar” business needs to evolve around the newer consumer behaviors in the virtual marketplace.  As surprising as it is, many companies like Toys R’ Us and Sears with decades of brand loyalty just could not make their model compete and evolve in […]

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Strong job market could mean small employers are getting “ghosted” how can you prevent it?

July 24, 2019

This week an interesting article came out in Fox Business (written in Motley Fool) titled “4 reasons hourly workers reject jobs – and what to do about them.”   Many of small business owners in Texas could be seeing a rise in the so-called millennial generation phenomenon of “ghosting.” According to the Urban Dictionary “Ghosting” means the shutdown/ceasing […]

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Texas Debt Buyer Bill is set to be signed by Governor Abbott

June 19, 2019

House Bill 996 a “Debt Buyer Bill” is set to be signed by Governor Abbott.  This particular bill limits when a debt buyer can initiate legal action or arbitration to collect consumer debt. It also requires specific notices to be provided to the consumer with respect to out-of-statute debt.  The new provisions are effective Sept. 1, […]

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AOC and Bernie get slam dunked over their anti-payday loan act.

May 24, 2019

Chris Talgo, a columnist at Townhall.com did a phenomenal job on his recent column regarding Bernie Sanders and AOC’s Loan Shark Prevention Act.  I would say he slam dunked the pair’s “Act” quite nicely.  Within the piece, several hard-hitting facts & statistics were used to counter many assertions made by the two in their recent […]

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Sunset process continues with the OCCC next up is the Stakeholder Meeting to discuss rule amendments.

May 20, 2019

Laurie Hobbs at the OCCC sent out an email to industry “Stakeholders” on Tuesday regarding the continuation of the Sunset process at the OCCC.  Next up is the Stakeholder Meeting to discuss rule amendments.  See below for OCCC’s comments on what will be done and how you can participate. “OCCC would like to inform us […]

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Snapshot on the progress of a five-location retail chain’s Search Engine Marketing Campaign after six months.

May 10, 2019

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 […]

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Submit your comments to the CFPB by May 15th

May 3, 2019

CFSA has been urging industry stakeholders to submit a comment letter to the CFPB regarding the  “CFPB Rule Proposal to Reconsider the 2017 Payday Lending Rule.”   Again, right now the CFPB ATR and Payment Provisions are on hold which is referred to as a “stay.”  See below for what CFSA is saying we need to do, go […]

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Borrow Smart

Borrow Smart

What is Borrow Smart? It is a compliance program for Credit Access Businesses in Texas.

Borrow Smart: A Compliance Platform
• A shared compliance resource and support system.
• Internet platform for reference, Q&A, and quick response.
• Policy and procedure products, along with training and communications.
• Managed in partnership with other industry associations.
• A communication vehicle to disperse rules and regulations instantly.
• Built for Credit Access Businesses by Credit Access Businesses, in a language they understand.

OCCC & CFPB Compliance
• Specific education and guidance on OCCC rules for payday and auto title loans.
• CFPB Examination Manual review and discussion.
• Collaboration with OCCC and CFPB to learn priorities and communicate to operators.
• Communication on CFPB matters and preparation for future action by the agency.

Industry Oversight
• Assess compliance weaknesses of Credit Access Businesses in Texas and provide solutions.
• Monitor discussions of new laws and regulations.
• Track, categorize, and help resolve consumer complaints.
• On site compliance audits conducted by third parties.

Building a Foundation for Financial Success: A Financial Education Program
• A basic financial education seminar on budgeting, understanding credit, and saving.
• Currently offered across the Southeast to high school and junior college students.

E-Learning System: Web-based Training for Store Associates
• Easy to use online resources and tools for continual training.
• New hire training and refreshers.
• Full-time support for store associates, access to Borrow Smart 24/7.
• In-store manuals and reference guides, along with consultation when needed.

For Now…
• Borrow Smart should be shaped as the conversation dictates during Texas’ 83rd Legislative Session.
• New rules and regulations that result from the session can be disseminated quickly and uniformly.
• Changes to Best Practices can be communicated, adjusted, and distributed quickly.

Real Results
• A visionary program with a long-term perspective.
• Increases accountability for Credit Access Businesses in Texas.
• Saves state resources by relying upon an industry with a self-regulated compliance program.
• Encourages competition while allowing the market to decide rates and loan options.
• Ease of burden for operators will likely result in lower rates, and better service for consumers.
• Texas CABs will be in position to pass CFPB and OCCC examinations with flying colors.
• Makes Texas a leader in the US with the largest and most innovative payday compliance program.

Borrow Smart is a concept initially shared with CAB Consulting by the good people at Borrow Smart Alabama, namely a gentleman named Max Wood. For more than a year, CAB Consulting and Borrow Smart Alabama have been discussing ways to bring the Borrow Smart concept to Texas. The time is now, and with the legislative session in full swing the strengths of Borrow Smart should be offered up for consideration by all Texas CAB stakeholders.

As Borrow Smart in Texas begins to get traction, let’s consider how the industry as a whole can benefit from the uniformity, accountability, and consumer financial choice that Borrow Smart strives to ensure. Call or email Michael Brown with CAB Consulting to discuss at 214-293-8676 or Michael@CreditAccessBusiness.com.

Borrow Smart Alabama has many online resources available – take a tour by clicking on the links below. Let’s tailor Borrow Smart to Texas – imagine the possibilities!

Borrow Smart Alabama Financial Education: http://www.borrowsmarteducation.com/

Borrow Smart Alabama Compliance Overview: http://www.borrowsmartcompliance.com/

Borrow Smart Alabama Code of Fair Lending: http://tggtest.com/BorrowSmart/code.htm

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With an eye on FinTech Lending what can we learn from our lead selling that will help us approve more loans without assuming more risk.

With an eye on FinTech Lending what can we learn from our lead selling that will help us approve more loans without assuming more risk.

by The CAB Man Texas on November 5, 2020

Some stores need deeper assessment and others do not because they are excellent performers.  Let’s look at one store and with the desire of loosening up in some areas where perhaps underwriting is too tight.   Dylan and Jeremy at Cashmax call it “turning a knob” or “moving a lever.” Let’s move a knob or lever with this one store and see what happens.

Doing an assessment and would love TOFSC opinions.  First, we are looking back at recent leads that have been sold through a lead buying network, what are others paying (we are going to assume it is a “FinTech”) for the leads they buy from you? After studying the sold lead what are your takeaways? If the smart FinTechs with all the “AI” and “Machine Learning and “Data” who own over half the Texas market are going for approvals with these customers who apply through you, then how can you learn from that and instead approve more for yourself versus letting go of potentially good paying customers?  See below for some key data points from three recent sold applicants.

$88 – Customer A:

No FT ran.

Online app – Google

Time at address: 5yrs

Time at bank: 2yrs

Bank: Bank of America

Time at employer: 7yrs

Employer: Filtration Group

Income: $6,594.77

**Customer was denied for having too many open loans and frequently being negative. He has loans out with Lend nation, Cash Store, Check n Go, TX Car Title & Payday, World Finance, Integrity Funding, and Easy Financial.

Comment: long time at address, bank, and employer, strong income over $6k, tons of loans out and the buyer did not care.  Also, did not care about account being so far in the negative. 

$83 – Customer B:

FT: 111

Online app – Google

Time at address: 2yrs

Time at bank: 2yrs

Bank: A+ FCU

Time at employer: 5yrs

Employer: Travis County

Income: $3,600 (per app)

Comment: customer was denied for having too many open loans. FT shows loans with a total of $4,508 in outstanding balance. On her banking it shows Credit Ninja ($700 borrowed on 09/14) and Cashnet ($800 borrowed on 08/03).

$18.50 – Customer C:

FT: 111

Online: Google

Time at address: 3yrs

Time at bank: 8yrs

Bank: United Heritage CU

Time at employer: 3yrs

Employer: HCA Healthcare

Income: $2,500 (per app but it was verified at $1660.91)

Comment: FT denied due to having too many open loans and too many loans in collections. FT shows 5 loans totaling $897 outstanding balance and 3 loans in collections. However, we cannot find any loans in her banking history.  Lower income and thus a lower sale amount.  But address, bank, and employer were in the same ranges as the other two customers above.  So, is the income the key factor here? Does that trump all other concerns?

Another one of our generous members shared his opinions on lead sales and how quoting lower first-time loan amounts can hinder growth”

“Typically, a loan selling for greater than $50.00 is auto approved with VERY little underwriting with Fintech. The issue you may run into is loan amount. The consumer most likely will not be interested in a loan less than $500, and sometimes the amount of fees will drive them away. But I would most definitely always reach out to them. Sometimes a local company makes them feel more comfortable, and you can close the deal. Regardless, a lead that sells for greater than $50.00 is a very good lead and most definitely worth your time to reach out.

Going further with the assessment: pull the last (3) months of denial reasons, break that out by month, by store.  Look at what the largest set of denial reasons is per store.  Perhaps loosen up in one of the largest areas of denial.  Maybe go one or two layers on the 2nd and 3rd most common denial reason and.  Loosen slightly implement the lever move with the lowest perceived risk.  Might that lever be “too many loans out” if the income is there? How far will you go on a negative balance?  Also, per the comments above, go back and look at the leads that have sold over the last (3) months over $50 to study again and see what patterns exist.   

Would love to hear from our clients, TOFSC members, and industry friends on this.   Send feedback where you can!

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What We Do

What We Do

Experience areas are listed A – Z.  Scroll down to read!

CAB Manual

The CAB Manual contains the basic information needed to start the licensing and compliance transition process. Ordering this manual from C.A.B. Consulting and Brokerage will assemble all necessary elements to begin the transition process, eliminating the need to go to more than one place for initial information, guidance, and paperwork. The manual materials are offered in print and online for our client’s reference when needed. Summary of included items:

•Transition process summary and opinion letter with important information related to the new license and licensing process
•Compliance summary and opinion letter with important information related to notices and disclosures
•Reference copies of important laws and regulatory publications
•Rules summary with interpretation and comments
•License application documents
•Inclusion of company members to the CAB Consulting and Brokerage Newsletters, Emails, and RSS Feeds

Collections and Debt Sale

C.A.B. Consulting and Brokerage has a unique relationship with a debt selling platform that assists clients in liquidating their bad debt portfolios quickly and easily to the highest bidder.  Finding the right source for this end of your business is critical, and partnering with the right people is step one.

Competitive Advantage

The most competitive businesses provide benefits to customers beyond just a payday loan in exchange for their commitment.  C.A.B. Consulting and Brokerage possesses a set of specific opportunities that are available for companies to utilize in this manner.  Let us work with you to implement new programs that broaden your relationship with your customers.  Providing benefits and increasing communication will give your business a competitive edge in a crowded marketplace.  Also, improving the company image and marketing online is an area of great need for our small to midsize payday loan clients.

Compliance Consulting Services

C.A.B. Consulting and Brokerage works for Texas CAB’s who are planning a transition towards a new Credit Access Business license or those who already have.  We are all still relatively new to “CAB,” so a continual review is smart, where one might pinpoint potential red flags, and gain more understanding the laws & rules.  C.A.B. Consulting and Brokerage has turn-key plans ready to ensure that each CSO-CAB we work with will have their license request approved, be prepared.  We are also working with an on-site independent auditor who can do audit files and troubleshoot problems in stores across Texas.

Consumer Loan Contracts

Many operators invest thousands of dollars with industry experienced attorneys to have their Consumer Loan Contracts written.  While it is always recommended to consult an attorney, some operators choose to rely on the contracts generated by their software company.  At times, these documents are used by many different clients of the software company, are basic, and do need re-working so they can be precisely applicable to your business.  CAB Consulting offers a set of Consumer Loan Contracts that have been written by an industry experienced attorney.  And, over the last 18 months CAB Consulting has worked hard to make improvements on the contracts as OCCC rules and regulations began to be more clearly understood by the industry.  Having a strong set of Consumer Loan Contracts is a top priority and a great way to ensure a passing grade in your next OCCC examination.

Corporation Startup, Filings, and Formation

The filing of corporate setup documents for LLC’s and Corporations is something that CAB Consulting ended up being positioned to do more for convenience of the client and the saving of time.  Working through Texas SOS and the IRS website to get a Tax ID #, Register a Business, or file an assumed name certificate can be done much more quickly by CAB Consulting versus some of the other “pay for service and filing” companies online.

Education

C.A.B. Consulting and Brokerage aims to be the go to source of information as payday and auto title loan businesses transition from Credit Service Organizations to Credit Access Businesses.  January 1, 2012 was the mandated date for all current payday and auto title loan operators in Texas to be certified as CAB compliant businesses.  C.A.B. Consulting and Brokerage will not only educate clients on the details of the transition, but develop long term relationships to build stronger companies into the future. Small to mid-size operators in Texas need to be informed about the laws & rules, to be kept abreast of developing changes, and to maintain a continual focus on operating in a compliant fashion.  C.A.B. Consulting and Brokerage is building its business around the needs of these clients.

Investment Opportunities

From time to time CAB Consulting is approached by individuals and organizations that are looking to passively invest in the payday industry.  There are two channels in which this can be done: the Third Party Lender, or investment on the operator side with growth capital.  As well, startups and existing operators who are growing contact CAB Consulting to discuss their desire or need for investment capital.  If you need money for growth or have capital available for investment in the industry, contact us.

Licensing

CAB Consulting has helped dozens of entities get licensed in the State of Texas as a Credit Access Business.  We work with operators to prepare for the submission of the CAB Application, make sure its the best it can be, communicate with OCCC during the process, and handle any hiccups that come up along the way.  So far, not a single client we have worked with has been denied a license!

Marketing & Advertising Ideas and Strategy, Customer Customer Acquisition Plans

CAB Consulting has developed a wide array of different marketing and advertising ideas, plans, and strategies, both B2B and B2C.   When working with startups many times they are new to the business and considerable time must be spent with these clients on strategy, how to get customers in the door, and how to engage consumers once they are in the lobby.  Sample materials, web designs, referral programs, and dba recommendations are just a few of the areas where CAB Consulting can step in and help a startup get their business opened with tools for success.

Payday Boot Camps

Two close associates of CAB Consulting are Tri-House Consulting and Paid 2 Day, since June of 2012 our three groups have been putting on the “Payday Boot Camp.”  The Payday Boot Camps are two day in-store training sessions for persons interested in starting a payday or auto title loan business.  Typically, the clients fly in from their hometown location, and spend two full days in the Paid 2 Day store.  The agenda covers both a “macro,” and “micro” look at the industry, where the attendees are taken through detailed strategy sessions, their business plans are reviewed, commented on, and adjusted if need be.  Training in a “live” store also gives the attendees a chance to watch a loan get funded and see a payment get taken.  Instruction on in store compliance and store organization is also provided.  After the Payday Boot Camp our goal is for the operator to have a clear vision of where they are headed with their startup, and to go along with that they will have direct experience with some of the biggest keys to running  successful payday business.  Paid 2 Day is owned by Danny Verrette, a California payday lender in Lake Forest, about 50 miles South of Los Angeles.  The Paid 2 Day store is setup like a typical payday loan store, but also has offices and a conference room that are ideal for instruction during camp sessions.  Tri-House Consulting is headed by Jer Ayles-Ayler.  Jer is the original source behind the Payday Boot Camp and is also an industry leader, blogger, conduit, and overall expert in high level thinking when it comes to payday business.

Sales and Acquisitions

Because of the relationships we have in the industry many times CAB Consulting is approached by organizations that are looking to acquire businesses.  CAB Consulting has connected many existing clients to buyers and played a role in the many successful sale transactions.  Some deals have required full and complete leadership by CAB Consulting, and others have simply been the exchange of the contact information between parties.  Being a part of a multitude of deals has given CAB Consulting important perspective on how the process works, how to arrive at values for a business, market valuations, licensing transition, and third party lender issues that come along with the transaction.

Software Vendor Recommendations and Introductions

CAB Consulting has direct experience with many software providers in the payday industry.  Over time, we have accumulated a valuable database of information about these providers and have placed it all into CAB Consulting Software Matrix.   The Software Matrix is comprised of 50 important questions that every company should ask when evaluating what software option may be best for them.  The answers come directly from representatives of the companies and can be a huge time and money saver.

Supplementary Documents, Procedures, Checklists, Requirements

All of the “supplementary” documents necessary for business to operate can be provided by CAB Consulting.  Documents necessary for compliance such as Fee Schedules and OCCC Consumer Disclosures do take some time, and require the ability to calculate APR%.  As well, internally created documents like customer application forms, denial letters, privacy policy, requirements for approval, employee guides, and evaluation checklists are available to clients.

Third Party Lender Connections

An important component to the CSO-CAB is its choice of Third Party Lender. C.A.B. Consulting and Brokerage represents several entities who are actively seeking to step in as the lender for CAB approved businesses. If growth capital is a need for your business, C.A.B. Consulting and Brokerage has the necessary relationships to support your growth.

Variety of loan products: Payday, Title, Installment

The Credit Access Business license covers payday loans, auto title loans, and installment loans in Texas.  CAB Consulting directs its clients on each of these business models, can assist in development of fee structure, and provide competitive data on other CAB’s fee structure, state averages, etc.

 

 

 

Resources

Resources

The following service providers have been vetted and paid for inclusion on CreditAccessBusiness.com.

It’s advisable to check with multiple vendors and suppliers. Talk to their customers as well. The Texas Credit Access industry is dynamic and in a constant state of flux. Don’t hesitate to reach out to the Credit Access Business Team for specific recommendations.

 

CATEGORY SUPPLIER WEBSITE DESCRIPTION CONTACT
 Consulting  Credit Access Business Credit Access Business  100% focused on Texas CAB’s and CSO’s. Michael Brown: Founder Michael Brown
Organizations Texas Organization of Financial Service Centers http://tofsc.org/ Texas Industry Organization  TOFSC