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

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

$88 – Customer A:

No FT ran.

Online app – Google

Time at address: 5yrs

Time at bank: 2yrs

Bank: Bank of America

Time at employer: 7yrs

Employer: Filtration Group

Income: $6,594.77

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

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

$83 – Customer B:

FT: 111

Online app – Google

Time at address: 2yrs

Time at bank: 2yrs

Bank: A+ FCU

Time at employer: 5yrs

Employer: Travis County

Income: $3,600 (per app)

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

$18.50 – Customer C:

FT: 111

Online: Google

Time at address: 3yrs

Time at bank: 8yrs

Bank: United Heritage CU

Time at employer: 3yrs

Employer: HCA Healthcare

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Summary of presentation topics:

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

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

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

We are nearing the end of the Holiday Season’s high demand period that coincides with the beginning of Tax Season.  Many CAB Consulting clients and TOFSC Members offer Tax Preparation services, and some will be doing it for the first time this year.   I know many who are ready to get after it so let’s go!

Here are some things every business needs to know about 2020’s Tax Prep Season:

• IRS is expecting more than 150 million tax returns expected to be filed.
• W2’s are already going out, all must be out by end of January.
• Tax filing season is Monday January 27th through Wednesday April 15th.
• Refund advances are happening already.
• Expect heavy loan payoff trends to start mid-February.  
• In 2019, we saw largest payoff week of entire year fall on the week of February 24th to March 2nd which was the exact week when the Earned Income Credit consumers got their refunds and paid off.
• Earned income credit / additional child tax credit – consumers who seek these credits will get their refunds later.
• In 2020, this means that refunds for these consumers will not happen before February 15th.  In, 2019 it was February 27th so it is good that it is 12 days sooner.
• This is the 4th year where there has been a delay on tax refunds for those where the “PATH Act” applies (Protecting Americans from Tax Hikes Act). 

With the key information above you should be able to forecast where loan volume will go, when demand will wane, etc.  The Tax Prep market is very competitive but if you are committed it is a nice way to expand services to your existing customer base and grow an attractive additional revenue stream for your business.  If you have interest in adding these services, reach out to CAB Consulting for assistance!

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.

Why should Texas CABs keep an eye on FinTech Lending?  We need to watch and learn, let’s evolve our businesses by watching their successes and failures.  Where you can, implement their techniques that work, into your CAB’s capabilities! Think marketing, underwriting, process flow, etc..

These recent OCCC MSA report statistics show that FinTech now owns the Texas loan market which was not the case a few years back.

Q2 2019 OCCC Report said:

12 out of state online CABs did 67% of all single payment loans.

26 out of state online CABs did 49% of all installment loans. (comes out to $1.3 million per month in loan volume for those 26)

3 years ago the OCCC Q2 report said:

10 out of state online CABs did 50% of all single payment loans.

15 out of state online CABs did 28% of all installment loans.

Wow – just 26 CABs are now doing half of all installment loans executed in Texas.  Consumers are having their voice heard and it is saying “we love FinTech lending!”  Make changes that will mirror your FinTech competitors and tap into a massive market that you may be missing.

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.

Lending to Green Dot Card Customers – is this a good or bad idea?  Many feel these and other pre-paid card accounts carry too much risk because the card holders are not as “married” to the card versus the commitment assumed is had with a traditional bank with local branches. 

We had one TOFSC member call about working with Green Dot consumers and it was brought up that another well-known East Texas operator has been doing it with a high degree of success.  So TOFSC asked this former “CAB of the Year” and “TOFSC All-Star” to share his experiences with this so far. 

Below are some excerpts from the conversation…

Positives:

·         Accepting Green Dot has been viable for (4) years now.

·         Green Dot is loadable at a lot of places – this is good for customers because each load location really acts as a bank.

·         Green Dot cards have a routing #, acct #, bank statement, username, password.

·         Takes direct deposit, SSI, etc.

·         Some customers get paid 2 days early.

Negatives:

·         They offer a “vault” where vendor access to funds is blocked…so cardholders can turn card off / on.

·         Direct Deposit hits at 2am, sends alerts to customer that alert them to debit attempts.

·         You will lose all disputes on chargebacks.

Many storefronts may not be seeing many pre-paid cards as their system is pre-programmed to automatically deny applications with most of the common pre-paid card brands entered into the bank account field.   If you are ready to experiment with Green Dot (largest card brand in the US) then remove that filter and move forward with caution as you learn this niche of potentially higher risk applicants. 

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.

After not being able to find the CFPB monthly complaint report on payday loans last week, I found it Wednesday which was a bit later than normal.  The delay might have been because it is a different kind of report, it is focused on “older” complainants who were 62+ years of age.

This new format report focused on just one month, and discloses that payday loan industry had (23) complaints versus (27) in the prior month.  That is a 28% decrease and is very much in line with all of the other reports that have been released I believe this is #23.

There have been 1,610 CFPB complaints submitted on the payday loan industry since complaints started being taken in November 2013, and (60) “older complaints” have been submitted since November 2013.

Overall, 1,163,000+ total complaints have been submitted so far to the CFPB covering all industries not just ours.  1,610 o, so PDL has a .001387931 complaint ratio!

Here is a link to the CFPB’s published report:

https://s3.amazonaws.com/files.consumerfinance.gov/f/documents/201705_cfpb_Monthly_Complaint_Report.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.