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.

 

 

 

Texas Credit Access Business CAB Information

CAB Packet

The CAB Packet contains the basic information needed to start the licensing and compliance transition process. Ordering this packet 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 packet 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 packet 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 this package, contact C.A.B Consulting and Brokerage at cabconbrokerage@gmail.com or call 214.293.8676.

 

Texas Payday Loan Businesses – Take a CAB!

Texas Payday Loan Businesses – Take a CAB!

by The CAB Man Texas on September 2, 2011

What is a CAB?  Well, if you are a payday loan business in Texas, it’s now you starting January 1, 2012.

The title CAB stands for Credit Access Business, and along with the name change comes many changes for payday loan businesses. The current CSO (Credit Services Organization) model will evolve next year thus transitioning all payday loan businesses into CABs, which requires these businesses to comply with new regulations. Understanding the new regulations is vital to continuing your payday loan business.

Licensing is one portion of the CAB transition. Under Texas House Bill 2594, which addresses the new licensing process, current CSOs will be required to attain a CAB license and will be subject to a thorough review.   Applicants will undergo reviews not just of their business operation, but also of the principals involved with the CAB’s whose personal and business background will be requested.

What else is included in the CAB licensing process? A new application and detailed reports must be submitted to the state and an approval must be obtained in order for current businesses to operate legally after January 1, 2012. In addition, all Texas payday loan businesses must file quarterly reports, with the first being due April 2012.  The reports will summarize the prior three months of transactions and will be reviewed by the OCCC (Office of Consumer Credit Commissioner), which is the new governing body of the industry in Texas.  This process is new, it is an unknown, and will take some thought.  Are you ready to take this on?  In addition to the day-to-day operations of your payday loan business, you must create a plan to ensure compliance with the OCCC, which is a big undertaking.

The good news? CAB Consulting and Brokerage understands all the details required for your payday loan business to transition from a CSO to a CAB.  They’ve been in the payday loan business since 2003 and have recently participated in the rule making process at the Capitol in Austin to ensure thorough understanding of the CAB model and to voice preferences and concerns about proposed rules.

Don’t get bogged down by the details – contact CAB Consulting and Brokerage at 214-293-8676.   Let them inform you, handle the details of your transition, and execute the process so you can continue to do business in Texas.

Check back in for details about the new notices and disclosures requirements under the new CAB regulations.

{ 4 comments… read them below or add one }

Randy Olson May 1, 2013 at 10:59 pm

could you please send me some info about how we go about getting a loan office for Pay Day type loans started ? What license and how to apply would we need for Kerrville, Texas? What type of rules do we need to follow for our loans and where do we get a example of the contracts?
Thank you for any help you can give us.
Randy Olson

Reply

admin August 10, 2013 at 7:43 am

Hi Randy,

Congrats on your new biz. We’ve got sample docs, forms, and know-how for this. My team is focused on Texas payday ans car title loans.

Call me at 214-293-8676 Michael

Reply

Don Dunlap August 9, 2013 at 2:33 pm

I am brand new at this business idea and would like start up consulting advice

Reply

Anonymous August 10, 2013 at 7:38 am

Give us a call,Don. PH# on my web site

Reply

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Texas Payday Loan Businesses – Take a CAB!

Texas Payday Loan Businesses – Take a CAB!

by The CAB Man Texas on September 2, 2011

What is a CAB?  Well, if you are a payday loan business in Texas, it’s now you starting January 1, 2012.

The title CAB stands for Credit Access Business, and along with the name change comes many changes for payday loan businesses. The current CSO (Credit Services Organization) model will evolve next year thus transitioning all payday loan businesses into CABs, which requires these businesses to comply with new regulations. Understanding the new regulations is vital to continuing your payday loan business.

Licensing is one portion of the CAB transition. Under Texas House Bill 2594, which addresses the new licensing process, current CSOs will be required to attain a CAB license and will be subject to a thorough review.   Applicants will undergo reviews not just of their business operation, but also of the principals involved with the CAB’s whose personal and business background will be requested.

What else is included in the CAB licensing process? A new application and detailed reports must be submitted to the state and an approval must be obtained in order for current businesses to operate legally after January 1, 2012. In addition, all Texas payday loan businesses must file quarterly reports, with the first being due April 2012.  The reports will summarize the prior three months of transactions and will be reviewed by the OCCC (Office of Consumer Credit Commissioner), which is the new governing body of the industry in Texas.  This process is new, it is an unknown, and will take some thought.  Are you ready to take this on?  In addition to the day-to-day operations of your payday loan business, you must create a plan to ensure compliance with the OCCC, which is a big undertaking.

The good news? CAB Consulting and Brokerage understands all the details required for your payday loan business to transition from a CSO to a CAB.  They’ve been in the payday loan business since 2003 and have recently participated in the rule making process at the Capitol in Austin to ensure thorough understanding of the CAB model and to voice preferences and concerns about proposed rules.

Don’t get bogged down by the details – contact CAB Consulting and Brokerage at 214-293-8676.   Let them inform you, handle the details of your transition, and execute the process so you can continue to do business in Texas.

Check back in for details about the new notices and disclosures requirements under the new CAB regulations.

{ 4 comments… read them below or add one }

Randy Olson May 1, 2013 at 10:59 pm

could you please send me some info about how we go about getting a loan office for Pay Day type loans started ? What license and how to apply would we need for Kerrville, Texas? What type of rules do we need to follow for our loans and where do we get a example of the contracts?
Thank you for any help you can give us.
Randy Olson

Reply

admin August 10, 2013 at 7:43 am

Hi Randy,

Congrats on your new biz. We’ve got sample docs, forms, and know-how for this. My team is focused on Texas payday ans car title loans.

Call me at 214-293-8676 Michael

Reply

Don Dunlap August 9, 2013 at 2:33 pm

I am brand new at this business idea and would like start up consulting advice

Reply

Anonymous August 10, 2013 at 7:38 am

Give us a call,Don. PH# on my web site

Reply

Cancel reply

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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.

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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

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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.

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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.

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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

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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.

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