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

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

September 11, 2019

The New York Times ran a bit of an “expose” on “Earnin,” an online lending FinTech that may need to buckle up for a bumpy ride… It seems like each week there is a new Silicon Valley FinTech anti-payday loan venture that is launched with millions in funding and all the slick PR you can […]

Read the full article →

Back to School is here is your small business ready?

August 13, 2019

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

Read the full article →

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

August 6, 2019

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

Read the full article →

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

July 29, 2019

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

Read the full article →

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

July 24, 2019

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

Read the full article →

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

June 19, 2019

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

Read the full article →

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

May 24, 2019

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

Read the full article →

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

May 20, 2019

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

Read the full article →

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

May 10, 2019

For the benefit of those who read our posts we are sharing a snapshot on the progress of a five-location retail chain’s Search Engine Marketing Campaign after six months.  This particular business offers cash advances and title loans in the Central Texas area.  What do you think?  Is it doing well with SEO? Room for […]

Read the full article →

Submit your comments to the CFPB by May 15th

May 3, 2019

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

Read the full article →

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

Leave a Comment

Currently you have JavaScript disabled. In order to post comments, please make sure JavaScript and Cookies are enabled, and reload the page. Click here for instructions on how to enable JavaScript in your browser.

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.

Leave a Comment

Currently you have JavaScript disabled. In order to post comments, please make sure JavaScript and Cookies are enabled, and reload the page. Click here for instructions on how to enable JavaScript in your browser.

Previous post:

Next post:

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

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

by The CAB Man Texas on November 5, 2020

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

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

$88 – Customer A:

No FT ran.

Online app – Google

Time at address: 5yrs

Time at bank: 2yrs

Bank: Bank of America

Time at employer: 7yrs

Employer: Filtration Group

Income: $6,594.77

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

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

$83 – Customer B:

FT: 111

Online app – Google

Time at address: 2yrs

Time at bank: 2yrs

Bank: A+ FCU

Time at employer: 5yrs

Employer: Travis County

Income: $3,600 (per app)

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

$18.50 – Customer C:

FT: 111

Online: Google

Time at address: 3yrs

Time at bank: 8yrs

Bank: United Heritage CU

Time at employer: 3yrs

Employer: HCA Healthcare

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

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

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

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

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

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

Leave a Comment

Currently you have JavaScript disabled. In order to post comments, please make sure JavaScript and Cookies are enabled, and reload the page. Click here for instructions on how to enable JavaScript in your browser.

Previous post:

OCCC set to report to Finance Commission Friday

OCCC set to report to Finance Commission Friday

by The CAB Man Texas on December 18, 2019

The OCCC is all set to report to the Finance Commission this Friday, December 13th.  Below for the key take-aways for CABs offerring payday, installment, and title loans in Texas.  The report will compare September-October 2018 vs. 2019.  The Septermber-October 2019 part of the OCCC “fiscal year to date 2020”).

·         Examinations are down across the board at every license type except Pawn (89 in 2018 vs. 100 this year).

·         OCCC is reporting they are below target on exams and that they have been doing training and certifications.

·         As well, they are heavily focused on an “enterprise” examination of a large CAB that is taking up 20% of their focus / target.

·         CABs went from 13 examinations in the same period of 2018 compared to just 6 this year.   

·         For whatever reason CABs are way below all of the other license groups in terms of the “acceptable level of compliance” which is a term used for how well we are being examined.  We are hovering in the 55-65% range over thre last year whereas everyone else is in the 80-100% range.  This has been the trend since q4 2018 and would mean that us CABs have not been getting examined much and from our perspective many would agree.

·         Investigations – zero so far for payday and title categories in FY 2020 compared to just 1 on a title loan business same period last year.

·         Complaints – 8 in payday and 10 in title compared to 17 payday and 11 in title which is always good to report.

·         CABs are looking very good with their ratio of complaints to total licenses.  We are at .9 of 1,920 licensees which is at the lower end of the spectrum.

Link to the packet: https://www.fc.texas.gov/sites/default/files/2019-12/121319-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.

Leave a Comment

Currently you have JavaScript disabled. In order to post comments, please make sure JavaScript and Cookies are enabled, and reload the page. Click here for instructions on how to enable JavaScript in your browser.

Previous post:

Next post:

Tax Prep Season is here let’s get after it!

Tax Prep Season is here let’s get after it!

by The CAB Man Texas on January 9, 2020

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.

Leave a Comment

Currently you have JavaScript disabled. In order to post comments, please make sure JavaScript and Cookies are enabled, and reload the page. Click here for instructions on how to enable JavaScript in your browser.

Previous post:

Next post:

Resources

Resources

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

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

 

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

 

Keeping an eye on FinTech Lending

Keeping an eye on FinTech Lending

by The CAB Man Texas on November 15, 2019

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.

Leave a Comment

Currently you have JavaScript disabled. In order to post comments, please make sure JavaScript and Cookies are enabled, and reload the page. Click here for instructions on how to enable JavaScript in your browser.

Previous post:

Next post:

Helping Green Dot and other pre-paid card holders get funded on loans…good or bad idea?

Helping Green Dot and other pre-paid card holders get funded on loans…good or bad idea?

by The CAB Man Texas on November 21, 2019

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.

Leave a Comment

Currently you have JavaScript disabled. In order to post comments, please make sure JavaScript and Cookies are enabled, and reload the page. Click here for instructions on how to enable JavaScript in your browser.

Previous post:

Next post:

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.

Leave a Comment

Currently you have JavaScript disabled. In order to post comments, please make sure JavaScript and Cookies are enabled, and reload the page. Click here for instructions on how to enable JavaScript in your browser.

Previous post:

Next post: