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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The OCCC is seriously focused on Credit Access Business Examinations right now – are you ready?

The OCCC is seriously focused on Credit Access Business Examinations right now – are you ready?

by The CAB Man Texas on August 21, 2017

Over the last several weeks there has been a significant uptick in OCCC examinations of our Credit Access Business friends and clients.  Are you ready for the OCCC to walk in your door?  Chances are if you are a member of TOFSC or if you are a client of of CAB Consulting you are in a good position regarding software, APR% calculations, loan contracts, disclosures, and fee schedules.

That being said it is always good to get refreshers on where the OCCC may be looking the next time you come due for an examination.  If  you are in DFW, East Texas, or Houston I would make sure that you are ready to rock!

See below for some recent areas of emphasis:

  • TILA – is your APR% exact?  Are you off slightly?  Needs to get fixed asap if you are even slightly under-quoting.  Contact your software company ASAP.
  • Financial Privacy Act Notices – are the ones in your document package proper?
  • Credit Services Disclosure Statement – regarding the time frame consumer have to ask for information – are you quoting the proper number of days?
  • Updated OCCC Contact information – there was a change awhile back on this.  Did you update it?
  • OCCC Notice – must be plain to see and easy to find 1-click from the home page of your website.
  • Interest paid or to be paid to lender – this must also be disclosed on the Credit Services Agreement.
  • When selling a motor vehicle that has been repossessed – how many bids are you getting?

If you would like additional information on these areas feel free to reach out!

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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Examinations by the OCCC – show them you are tuned in!

Examinations by the OCCC – show them you are tuned in!

by The CAB Man Texas on August 6, 2012

Over the last 7 months CAB’s in Texas have evolved from a non-regulated space into the new CAB environment.  The OCCC has implemented its new way of doing things and there have been a few surprises along the way.

As a licensed Credit Access Business who has committed to learning the laws and made it a priority to study the rules outlining compliance, you are well on your way.   Do you have 100% confidence in how you have implemented Credit Access Business rules in your stores?  Have you talked with other friendly competitors about how they interpret the rules?   If you did, you might know that a preliminary round of OCCC examinations was performed.  There was some industry “buzz” from those examinations that gave many of us more of an idea of what’s to be expected.  The OCCC has been great to work with so far, for example what many would call their visits to your store an “OCCC audit”, they call an “examination.”  Seems to like a softer and friendlier term…

A commitment to gaining knowledge, operating legally, operating fairly, and exchanging information with peers is key to building confidence and securitizing your business.   So, how exactly might that be done?  Contact CAB Consulting and Brokerage!  We have created plans for our clients that create a simple approach to OCCC compliance.  CAB Consulting and Brokerage’s relationships across also put it in an ideal position to communicate recent developments and pass the latest “buzz” to your business.

Show the OCCC that your Credit Access Business is tuned in when their examination of your business goes smoothly and without any surprises.  Be an ideal CAB and get informed – make the OCCC’s job easy!   Start by contacting CAB Consulting and Brokerage to discuss how we might be able to go to work for you.  Reach Michael Brown at 214-293-8676 or via email at michael@creditaccessbusiness.com.

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Thank you for visiting Credit Access Business.com !

Thank you for visiting Credit Access Business.com !

by The CAB Man Texas on August 1, 2011

Are you a Texas CSO that is hungry for more information on the new license you’ll need by January?  You’ll need to evolve your CSO into the OCCC’s “Credit Access Business” model and we want to assist you in doing so.

Michael Brown may have contacted you or will be contacting you in regards to our Credit Access Business services.  Our areas of focus are Compliance, Capital, and Collections.

CAB Consulting and Brokerage Goals:

#1 – Learn more about your business and its unique needs.

#2 – Create a step by step plan to get to you compliant.

#2 – Provide you with options for operating Capital and 3rd Party Lenders.

#3 – Improve your Collections processes, and buy your Bad Debt.

We recently attended the OCCC stakeholder meetings and Austin and are informed on what is to come.  CAB Consulting and Brokerage is contacting CSO’s in Texas right now to share what we know, learn their needs, and discuss how we may be of service.

Please contact Michael Brown at 214-293-8676 to learn more today.  Or, email Michael at cabconbrokerage@gmail.com.

Thank you again for visiting Credit Access Business.com!

 

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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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Auto Title Loan Business Acquisition Opportunities on the Rise

Auto Title Loan Business Acquisition Opportunities on the Rise

by The CAB Man Texas on March 15, 2012

Auto title and payday loan business acquisitions are on the up, and demand is mounting as interest to expand business through existing locations continues to grow.

C.A.B Consulting and Brokerage is seeing this first hand and is further extending its brokerage efforts  to fulfill demand with the sale of three Texas auto title loan locations: a dual location Houston-area business; and a single location Dallas-area business.

Located in the Houston Metro area, the first auto title loan acquisition opportunity includes two locations, both situated in a prime strip center setting. The first location is an 800 sq. ft store with an affordable lease and no competition for miles. The second 1500 sq. ft store is in a preferred location with no competition in the immediate area. Leases have desirable terms, positive landlord relationships, and include no restrictions. Each turn-key location was built brand new two years ago and includes all furniture and office essentials. Both locations have their CAB license and have an ideal third party lender in place. Currently set up as an auto title loan business, these locations have the infrastructure in place to easily add payday loan services. The buyer is motivated and accepting offers for sale.

The second auto title loan acquisition opportunity is an established Dallas-area business. After six years, the business has established an ideal fee structure proven to be agreeable to customers that has resulted in consistent revenue and low defaults. The prime location is situated near a highly trafficked intersection in the Plano area. The lease has desirable terms, a positive landlord relationship, and includes no restrictions. The business has its provisional CAB license and a qualified third party lender in place. The location is currently set up as an auto title loan business, but includes the infrastructure to easily add payday loan services. The seller is seeking an immediate buyer and is accepting offers for sale.

C.A.B Consulting and Brokerage is brokering multiple sales of auto title loan and payday loan locations throughout Texas. Contact C.A.B. Consulting and Brokerage to sell your current auto title loan or payday loan business or learn more about acquiring businesses for sale.

Contact Michael Brown, principal of C.A.B. Consulting and Brokerage, at 214.293.8676.

{ 1 comment… read it below or add one }

Car Title Loans Austin TX October 30, 2013 at 10:16 am

There is no need to run a new credit history verify after you make application for an automobile title loan because it will be based upon the significance on the automobile. Car title loans are usually secured motor finance, which means that upon finalizing your own loan that you are affixing your signature to over your own car’s title towards bank. They then keep this title throughout the period on the loaning period.

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The infamous and continuously failing Texas Payday Loan City Ordinance.

The infamous and continuously failing Texas Payday Loan City Ordinance.

by The CAB Man Texas on August 22, 2017

Since Texas cities began passing the infamous and continuously failing Texas Payday Loan City Ordinance there has been a decrease of 1,300 or so licensed locations inside the State.  According to the most recent OCCC licensee totals, this represents a 37% market shrink.  The results have been a shuttering of businesses in Texas, a loss of thousands jobs, a loss of real estate rents, and decrease in property tax revenues.  Rates have increased 12% in Ordinance cities and demand for unsecured short term credit has largely remained the same.  This is a cold hard truth that was laid out in City Council meetings when we were asking for a “No” vote on the Ordinance.  Is an “I told you so” in order here?

2017 has been a rough year for the Ordinance though, many cities are now bucking the trend and have voted the Ordinance down.  As well, the City of Austin got the double slam-dunk in their simultaneous loss to Speedy Cash and Advance America City Ordinance lawsuits in April.  Those two cases were around a year in the making I wonder if the taxpayers of Austin feel good about the time and expense the City put into an issue that results in a .000153% complaint to loan ratio for Texas residents?  I live in Austin and things are tight budget-wise in this City, despite all the stories you hear about growth it has some problems that should be commanding the attention of city leadership other than the payday industry.

So here comes the next whammee – I was reading over the OCCC’s 1st quarter MSA report for 2017 and it says that 10 of the 2,200 reporting licensees generated 33% of the single payment loan volume, and get this, those 10 licensees were OUT OF STATE!  As far as installment loans go in Texas, 16 OUT OF STATE licensees funded over 37% of the 271,189 installment loan and refinance transactions in the 1st quarter of 2017.  Yes, these are out of state online lending companies who are licensed to do business in Texas but are not within the jurisdiction of any City.  That makes them free to let the market decide and boy did the market ever decide.  On either of the products mentioned – the out of state licensee group was the largest “market” in Texas.  The next biggest markets down were Houston and Dallas but it wasn’t even close to the out of state operators.  Check out the report for yourself below.

Here is a link to the MSA report: http://occc.texas.gov/sites/default/files/uploads/reports/cab-q1-msa-2017.pdf

Imagine if the Payday Loan City ordinance did not force the closure of all of those locations in Texas!  All of that businss would be taking place here in Texas.  Kudos to the online guys who are meeting the need but for obvious reasons we need to work to get those customers back!  I bet the OCCC wishes they had that extra $800,000 per year in licensing revenue.  And how about that $300,000 per year in contributions to the Texas Educational Endowment fund that is now lost?

The full ugliness of the Payday Loan City Ordinance is now beginning to show in the light.  Please pass this information along to your City Council the next time this issue comes up in your market – we are positioned to deliver the facts to them quickly and efficiently so that they can have the full story and move on to the next issue which will be much more meaningful, no doubt!

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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Bank Fees are rising and so is use of Alternative Financial Services – coincidence?

Bank Fees are rising and so is use of Alternative Financial Services – coincidence?

by The CAB Man Texas on August 14, 2012

I was reading this CNN Money.com article today: http://money.cnn.com/2012/08/13/pf/bank-fees-rise/index.html

This is an issue that I am very familiar with and the result is more customers for Texas Credit Access Businesses.

Monthly service fees on accounts with balances below $5,000 are the banks targets for the monthly service charges, which certainly fits the low and middle income profile of the typical payday consumer. And, don’t forget that NSF and Overdraft fees at many banks are have drifted up into the $35-$40 range.

Options like pre-paid debit cards are becoming more attractive compared to the bank branch, and in many cases the pre-paid cards offer more ideal online account management and smart phone capability, all with lower monthly service charges.

Consumers are learning there are more convenient and less costly options out there, and a migration towards cutting edge alternative financial services is happening. Shape your business accordingly, get creative, and stay convenient!

I refer to the information below very often in conversations – it is published by FISCA and illustrates the real deal on banking related charges versus payday advances – the APRs are less in many cases! Be sure and have these statistics ready the next time the APR topic comes up – and then nail it.

$100 Payday Loan (14 days) = $22.88 Fee (596% APR)
$100 Overdraft Protection = $29.00 Fee (756% APR)
$100 Bounced Check = $54.87 Fees (1,431% APR)

Sources:
(1) Bankrate.com, 2007 Courtesy Overdraft Study – based on average first draft
(2) Average NSF fee $28.23 (Bankrate.com, 2007 Checking Study), based on average first NSF charge, and average merchant return check fee of $26.64 (2006 CFSA fee survey).

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Website Design to Ensure Compliance with the O.C.C.C.

Website Design to Ensure Compliance with the O.C.C.C.

by The CAB Man Texas on April 3, 2012

C.A.B. Consulting and Brokerage works with Texas Credit Access Businesses on their licensing, compliance, operations, and third party lender needs. Recently they partnered with Orangebook Website Design to offer Texas CAB’s dynamic websites at a discounted price.

Per its Rules for Credit Access Businesses, the O.C.C.C. asks that certain documentation (Consumer Disclosures, Licenses, Fee Schedules, and Notices) not only be displayed in-store but also on websites through which Texas CABs advertise their services. Orangebook Website Design has been educated on the regulations and will redesign or build a new website for your business that ensures compliance in the internet marketplace.

Orangebook Website Design is offering Texas CABs a greatly reduced price for a new website build. Orangebook Website Design has reduced the list price for a 5 Page website from $975 to $745 for C.A.B. Consulting and Brokerage referrals.

5 Page Features ($745)

  • Complete Custom Web Design (No Templates)
  • Home Page Flash Intro
  • Unlimited Design Revisions
  • Contact Page with Contact Form
  • Search Engine Friendly Web Site
  • Social Media Links to Facebook, Twitter, and MySpace
  • Dedicated Contact Personnel for Your Project
  • Free Online Payment Interface
  • You Own Your Web Design – Onetime Cost for Web Design

An 8 Page website originally priced at $1,540 is now reduced to $1,185 for C.A.B. Consulting and Brokerage customers.

8 Page Features ($1,185)

  • All Features Listed for the 5 Page Website Design
  • Unlimited Photo Galleries
  • Video Upload
  • Unlimited Slide Shows
  • PDF File Download

Website redesigns start at $595 and include all the features of a new website build. E-Commerce Websites are available at a reduced rate of $1,775, and, in addition to all the listed features for website design, includes a Shopping Cart System.

Website Hosting services are also available through Orangebook Website Design:

Basic Hosting ($37.50 a month)

  • 24/7 Web Maintenance
  • Unlimited Changes
  • SEO
  • Contact Management System

Premier Hosting Services ($89 a month)

  • Development of a Marketing Plan
  • Organic SEO
  • Content Development
  • Web Analytics and Analysis (evaluate weekly/monthly web traffic)

Orangebook Website Design provides personal website design services and has a portfolio of current websites, which include a wide variety of industry. Contact Orangebook Website Design at 949-715-5676 to further discuss the C.A.B. Consulting and Brokerage Website Design Discount.

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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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