CAB-New Way

CAB-New Way

The Credit Access Business (CAB) is the new model in Texas for payday loans. In 2011, the Texas State legislature was embroiled in a battle to pass legislation to regulate the payday loan industry. Legislative sessions occur every two years in Texas and for at least the last three sessions, lawmakers and payday loan industry advocates have engaged in heated debates that did not produce any laws or regulations. The 2011 session finally produced two bills that were passed into law, House Bills 2592 and 2594.

With the passage of these laws, the official Credit Access Business license stepped in front of the once all encompassing and vague Credit Services Organization (CSO) model. The CSO model, registration, and need for a Third Party lender still remains, but, in 2012, the Texas government will close a once wide loophole with CAB regulations.

House bill 2594 requires that CSO’s who want to operate in the payday loan space now be licensed as a Credit Access Businesses (CAB) effective January 1, 2012. The new licensing process will consist of a thorough review of the former CSO by the new governing body of the payday loan industry, the Office of Consumer Credit Commissioner, or the OCCC. Applicants will undergo reviews not just of their business operation, but also of the principals involved in the CAB whose personal and business background will be requested. In addition, H.B. 2594 added more fees that licensees will be required to pay versus the past CSO registration. Lastly, quarterly transaction report filing is required by the OCCC, the first of which will be due in April 2012.

House Bill 2592 outlines new requirements related to notices and disclosures to maintain compliance as a CAB. Integration of new notices and disclosures are outlined for both retail and online marketplaces. Changes to customer documentation and procedures related customer communication are part of this bill’s intent, which is to clarify facts, monetary figures, and educate all consumers about the business arrangement. For example, CABs will need to cite other financial resources for customers beyond the payday loan option, discuss these options with customers, and post alternative lending choices in stores or online.

There are many details to discuss to fully understand the broad intent of the bills before January 1, 2012. The OCCC hosted several collaborative stakeholder meetings in the summer of 2011. Business owners, consumer advocates and those who will govern the industry all participated in collaborative conversations about the bill’s intent and real world implementation of new rules. The final version of rules related to the new laws is due to be released in October 2011.

 

OCCC will be reporting to the Finance Commission Friday, October 18th.

OCCC will be reporting to the Finance Commission Friday, October 18th.

by The CAB Man Texas on October 22, 2019

The quarterly Finance Commission Meeting will be this Friday, mostly information will be reported for September to August 2018 vs. 2019…that is their fiscal year.

OCCC will report that:

·         Examinations were down in 2019, went from 638 to 475.

·         CABs went to the bottom in terms of acceptable level of compliance…due to lower examination volume.  This likely means they will get back to CABs soon with a increase in examinations for us.

·         Zero investigations were done in the last year, versus 3 in the prior year.

·         Complaints for payday: down, from 114 to 97.  (down 15%!)

·         Complaints for title loans:  down, from 85 to 59. (down 30%!)

Market Trends for Q1-Q2 of 2019 vs. 2018 were reported versus the fiscal calendar info above:

·         Repo totals are trending upwards and it is thought by the OCCC to coincide with longer payment terms. This was a specific comment, outside of the charts provided and that makes the topic significant. 

·         The OCCC is monitoring this issue to see if it levels out or needs compliance emphasis so head’s up there.  Repo is precarious and they do tend to look deeply into it.  Be 100% dialed in with your compliance measures on this topic, make all of the proper disclosures, send the notices at the correct intervals, and maintain records with excellent organization.

·         # Customers obtaining unsecured loans went up!  In 2018 it was 787,700 and in 2019 it was 799,292 or 1.5% increase.

·         # Customers obtaining title loans went down.  In 2018 it was 135,619 and in 2019 it was 129,163 or 4% decrease.

·         Repossessions went up 32% to 22,005 from 16,620.  These have been hovering in the 16-18k range since 2015 but 2014 had 20,879.

·         There are now just 1,756 locations reporting activity.  Down from 1,832 which is a 4% decrease.

Here is a link to the packet (go to page 249): https://www.fc.texas.gov/sites/default/files/2019-10/101819-fc-packet.pdf This blog post was written by Michael Brown, President of CAB Consulting and the Texas Organization of Financial Service Centers.  He can be reached at 214-293-8676, or Michael@CreditAccessBusiness.com.

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Did you know that Payday and Title loan business owners in Texas have rules that dictate where services can be marketed and advertised?

Did you know that Payday and Title loan business owners in Texas have rules that dictate where services can be marketed and advertised?

by The CAB Man Texas on November 18, 2016

We are at a point in the year when many Credit Access Business owners who offer payday, installment, or title loans to Texas consumers increase their marketing and advertising efforts in hopes of serving those needing an extra financial cushion to get through the Holidays.  It is important that readers know there are some restrictions around off-site advertising.

Per Texas Finance Code Chapter 393, a Credit Access Business may not advertise on the premises of a nursing facility, assisted living facility, group home, or intermediate care facility for persons with mental retardation, or other similar facility subject by regulation of the Aging & Disability Services.

It is my opinion that many of our clients and members would not intentionally advertise or market to these consumer groups.  But, we should all be aware that employees who are out and about hanging door hangers, passing out flyers, etc may not think about it while they are on the premises of such facilities.  So, just head’s up and let’s all make sure we are thinking a few layers deep while we are working through a high demand higher action period of our business cycle.

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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Military Lending Act Questions

Military Lending Act Questions

by The CAB Man Texas on November 21, 2016

As many of you may know, in October 2016 we all began operating by new rules in regards to how we must treat “Military” applicants and their dependents.  We now need to verify what has been told to us by the applicant regarding their status on this topic.  The burden is on us as operators to confirm the status versus the past where the applicant simply checked the “yes” or “no” boxes on the application form or on the consumer loan documents.

You can go directly to the Department of Defense’s MLA website to perform the checks or if you employ Credit Reporting Agencies like Factor Trust or Microbilt they have the checks integrated.  Here’s a link to the MLA website: https://mla.dmdc.osd.mil/single_record.xhtml

My very close personal friend and true Southern Gentleman Max Wood at Borrow Smart Alabama put out the following thought provoking questions on this Military Lending Act topic and I wanted to pass those along to our site visitors.  Please review and due your part to make sure your operation is as strong as it can be on this subject!

1. Will will be violating SCRA rules if we don’t rewrite an existing customer who on paper said they were not a covered borrower but when accessing the DOD we discover they are?

2. On a busy day, clerks want to run DOD reports in the morning for all customers due that day so they won’t have to slow down the loan making process during the day. Is this acceptable or do they have to run reports only when customer is standing in front of them?

3. How will we determine if someone is the dependent of an active member in the military or reserves without having that family members information?

4. Will we need to continue to check the DOD website after the first advance of someone is permanently disabled, or is of social security age?

5. Will the following provide safe harbor: MLA website, “big three” credit bureau, SCRA website, retail credit report ostensibly re-reporting from “big three”?

6. If a product APR is too high for Military but was obtained pre-military, may it be re-financed with or without additional credit (not a payday loan)?

7. Does the database search cover all exposure for noncompliance with MLA?  In other words if the database search is performed and comes back clear does that cover any possible violation?

8. What exposure do we have for spouses, family members for this.  What are some of the questions we need to ask to determine all related persons to the applicant are covered?

9.  If the website is down when the search is performed is it enough to document that and have them sign a disclaimer stating that they are not an active member of the military.  Would it be a good       idea in this case to run a search after the site is up and document the file?

10. My understanding of this is basically when a new contract is executed a search has to be performed.  What are the exceptions to this?

11.  For an installment  loan renewal does a new search have to be performed when the loan is renewed?

12. For a flex loan (open line of credit) do we need a search when the customer takes out an advance on their existing line?

13. For a Tennessee Title Pledge loan do we have to do the search prior to sending a renewal letter for an extension?

14. Is there any reason to take existing Military Act questions off of the existing contracts?

15.  Is there anything that needs to be done re pre-10/3 loans (e.g., scrub against the database)?

16. Do MLA restrictions apply to “mere” loan extensions?

17. In AL a title pawn is actually a traditional pawn transaction (title is held as merchandise for pawn) – unlike most other states.  At the end of 30 days the customer may pay the fee (interest) and extend for another 30 days.  There are a couple of ways people do this.

a) After the initial transaction and contract each subsequent extension is done by accepting the payment and extending for another 30 days.  If the loan amount increases the old contract is paid off and a new contract is generated that reflects the new amount.  This transaction type would require a check of the database, I am sure.  BUT, if there are no changes or principal is paid down and only a receipt is printed, is a check of the database required?  To further complicate the situation some operators use a different pawn number for each extension and others do not change the number.  Would a check of the database be required under either or both scenarios?

b) A new contract is generated at each extension.  My guess is that a database check will be required.

18. If a lender is in compliance with the new MLA rule including the database check, is there a problem with a lender continuing to obtain a signed military form (the model form) for our files in addition to the new required database check confirmation certificate ID number?

19. Are there any prohibitions to refusing to lend to a covered borrower?

20.  A new customer divorced her husband who was active duty.  She received no spousal support in the divorce yet her MLA search lists her as a dependent.  The database had not been updated to reflect her as no longer deriving income from her now ex-husband.  Is it acceptable to provide a loan to the customer as long as income and divorce documentation is provided?

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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Fun with the filing of liens on Motor Vehicles in Texas.

Fun with the filing of liens on Motor Vehicles in Texas.

by The CAB Man Texas on November 17, 2016

Dealing with Texas DMV office who refuse to allow Credit Access Businesses to add a lien to a vehicle (for a Title Loan)  when the registered owner of the vehicle has outstanding warrants, tickets, toll fees and or recent child support payments on file as delinquent can be a problem.  We have seen this in a few counties recently – it appears to be referred to as a “Scoff Law”.

The only fix we have seen that works is to simply process the lien in a different county. There are 254 counties in Texas, and each tend to do their own thing!

Another instance that has come up with some title loan borrowers is when one consumer who has a title loan with a CAB sells their motor vehicle to another consumer without the buyer getting the title.  The buyer in these cases can either be tricked into doing this or may just be careless / unaware.

For the CAB in this case, because they actually have the title and the lien, they “own” the vehicle and would be forced to repossess if the seller stops paying on the loan (this would be what triggers awareness of any issue other than if the buyer comes back later and asks for the title).

If you find yourself in this predicament as a buyer or a CAB, follow the law and rely on other professionals to consult you on the best course of action.  For CABs (as always) follow the proper disposition methods in compliance with Texas Business and Commerce Code Chapter 9.

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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CFPB’s 16th Monthly Complaint Report released on October 25, 2016.

CFPB’s 16th Monthly Complaint Report released on October 25, 2016.

by The CAB Man Texas on November 1, 2016

I always look forward to the new CFPB complaint reports that come out each month around the 25th.  Why?  Well as you will see if you follow them as well, the “Payday Loan” industry (this is the umbrella term used in these reports to refer to companies who offer payday loans, installment loans, title loans, cash advances, etc) has yet another double digit decrease in complaint volume versus the same 3-month period (July-August-September) last year.  This month showed a 21% decrease.

It is unfortunate that there were complaints, and I can tell you that our clients would be extremely concerned in the event any complaint was filed by their customer.  They would respond promptly and work to communicate with the customer to clarify any misunderstandings and work out a resolution.  Zero complaints – that is the goal.

As is the case with the other monthly reports – we are always the industry with the largest decrease.  There are 10 other industry categories and we are the only one with these giant drops in customer complaints, consistently.  Student loans are #1 and our bank friends are at #2 with a 37% increase.

I am aware that consumer advocates and others who are not so friendly to the industry visit this website.  I am wondering if they also view the CFPB complaints each month.  The story being told here is that consumers complain less about our services than any CFPB category.  I would recommend you shift your focus to the biggest offenders if you are currently hyper-focused on shutting down the “payday loan” industry.

After all the work you have done to work up complaints you have only mustered a double digit decrease in complaint volume, you may be able to do better somewhere else.  I think the banks are where you should go – they target our customers with abusive overdraft charges and NSF fees with astronomical effective APR’s (think 1,600.00%), and bring in about 4 times the amount of annual revenue that our industry does.

Here is the link to this month’s report (see page 4):

CFPB October 2016 Monthly Complaint Report

This blog post was written by Michael Brown, President of CAB Consulting and the Texas Organization of Financial Service Centers.  He can be reached at 214-293-8676, or Michael@CreditAccessBusiness.com.

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Texas Organization of Financial Service Centers donates $10,500 to purchase ballistic vests for Longview Police Officers.

Texas Organization of Financial Service Centers donates $10,500 to purchase ballistic vests for Longview Police Officers.

by The CAB Man Texas on November 17, 2016

LONGVIEW, Tex. – Spurred by the senseless shootings of police officers in Dallas and elsewhere and promoting strong support for local law enforcement, four members of the Texas Organization of Financial Service Centers (“TOFSC”) have donated $10,500 to the Longview Texas Police Association to purchase ballistic vests.

The four companies making the combined donation — Texas Star, CashMax, Texas Thrifty Loans and Rapid Payday & Title Loan — operate storefront businesses in Longview and appreciate the outstanding public service and professionalism of the Longview Police Department.

“We have been overwhelmed with the outpouring of support from our community here in Longview,” said Sgt. Jimmy Purdon of the Longview Police Department. “Ballistic plates are a necessity for law enforcement in today’s climate. Officers need the highest level of protection available so they can go home to their families and continue to serve and protect our great community.”

The Longview Back the Blue support group has been raising money for the vests. Christy Purdon and Scarlet Bird launched the effort following the tragic July 10 shooting of five police officers in Dallas.

“Watching so many suffer such great loss made it even more apparent that we as a community needed to step up and do whatever we can to protect our officers,” said Christy Purdon, who is married to Sgt. Jimmy Purdon. “It is my belief that every officer across the nation deserves to be protected in the line of duty. They protect us each and every day, so why shouldn’t we protect them, too?”

Jay Pruett, owner of Texas Star, helped spearhead the donation for the vests.

“What we’ve seen — not just in Dallas but in too many places around the country — has been the horrific targeting and shooting of police officers,” Pruett said. “The police in Longview literally put their lives on the line everyday for us. This is the least we could do for them.”

Longview Police Department Detective Chris Bethard said he is “humbled and in awe of the generosity and support for law enforcement in our community.”

“In my 18 years of law enforcement, the climate of this profession has changed dramatically,” Det. Bethard said. “Due to those changes, the addition of ballistic plates has become a necessary piece of equipment to keep officers safe and give us the best chance of returning to our families. My family and I want to thank you for the support and dedication you give us as we serve this wonderful community.”

Ballistic vests costs about $800 a piece. With more than 100 commissioned officers, the Longview Police Department did not have the budget to purchase vests for every officer.

“I would personally like to show my gratitude to this group of businesses that reached out to me to show their support,” Christy Purdon said. “Their care and love for the community and its officers is heartfelt and will never be forgotten. There are truly no words that could ever show this group of businesses how much this donation means to us.”

Before the Back the Blue effort began, Scarlet Bird had never met Christy Purdon. But like Burdon, she has a strong and emotional connection to the Longview Police Department. She is engaged to Sgt. Donald “Chip” Koepke. The couple met when Sgt. Koepke saved Bird’s sister’s life after she was in a car accident.

“Over the last several months, we have helplessly watched the countless attacks on law enforcement,” Bird said. “Innocent officers have lost their lives for no reason other than being a police officer. I felt the need to make a difference.”

With a goal of raising $80,000, Longview Back the Blue began selling t-shirts and offering the opportunity for businesses and individuals to “sponsor” an officer’s vest.

“We are proud to be part of a community that supports our officers and their needs,” Bird said. “As we continue to work toward our goal, we strive to let the community know that no donation is too small; no act of kindness goes unappreciated. Along with contributions from other groups, we are just shy of the halfway mark in raising funds to outfit Longview’s patrol officers.”

The contribution from these companies is a strong example of how TOFSC members support communities across Texas, said TOFSC President Michael Brown.

“Our members are active in their communities,” Brown said. “They know their customers and they support and respect the job done by all law enforcement officers.  TOFSC is proud to be part of an effort that protects those who protect us.”

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 admin 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).

{ 1 comment… read it below or add one }

Jer – Trihouse August 22, 2012 at 8:07 pm

Michael,

You made some great points in this piece. Too bad the regulators are not informed. Not only do bank NSF fees translate into higher APR’s than payday loan products but additionally, more than a few banks (Wells Fargo for example) are offering products that compete directly with payday loans. The banks debit these customers the moment their customer’s payroll check is deposited; NO RISK to the bank!

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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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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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