Texas OCCC issues advisory bulletin to licensees on how to remain in compliance while dealing with Harvey aftermath

Texas OCCC issues advisory bulletin to licensees on how to remain in compliance while dealing with Harvey aftermath

by The CAB Man Texas on September 8, 2017

Our friend ROb Norcross at CSAT sent over some really good details that he had gathered in response to the OCCC issuing advisory bulletins to licensees on how to remain in compliance while dealing with Harvey aftermath.  I scraped some of those details and organized them below for CAB stakeholders in Texas, and business owners in general that were affected by Harvey.

CAB Consulting and TOFSC have clients and Members in the Coastal region and many were impacted – see below!

“The Texas Office of the Consumer Credit Commissioner issued an advisory bulletin reminding pawn shops of their obligations in statute and rule about safeguarding pledged goods, record retention requirements and relocating to temporary locations (see link in the email below). 

There are no similar provisions in Texas Finance Code Chapter 393 for credit access businesses. Sections 83.308 (b) and (c) in Title 7, Part 5 of the Texas Administrative Code addresses the relocation of transactions from one store to the other Section (c). Section (b) contains the notice requirements for customers and to the OCCC. Section (c) also provides for a waiver of the 5 day notice period by the Commissioner in cases of emergency. 

If one of your stores is damaged, and you choose to send customers to other nearby stores, please take care to follow these procedures. The provisions of your contracts with your customers will govern issues related to due dates, fee calculations, etc. 

The Code prohibits the relocation of a CAB store unless 30 days’ notice is given to the OCCC. There is no waiver provision for an emergency. However, if one of your stores — that is not near another store — is damaged, please contact the OCCC if a temporary location is the only reasonable solution to protect your customers. Despite the absence of a waiver provision in the statute, the OCCC has made reasonable accommodations to protect consumers with all types of licensees in the case of emergency. 

County Sheriff’s Office

If one of your employees has a question about local hurricane relief activities, law enforcement procedures during/after a hurricane, customers applying for federal assistance, shelter availability, etc., please do not hesitate to contact the local county sheriff’s department. Sheriff’s offices are a critical source of information during disaster recovery efforts. They are trained to navigate the varying levels and overlaps of local, state and federal bureaucracy and often serve as a counties’ switchboard during disaster recovery.

Do not spend hours on the telephone being transferred from FEMA official to FEMA official — call your local county sheriff’s office. They will (literally) tell you where to go…

 IRS Extends Filing Deadlines for Hurricane Harvey Victims

The Internal Revenue Service is giving Hurricane Harvey victims extra time to file individual and business tax returns and to make certain tax payments in 18 Texas counties because of the “devastating storm.” Businesses and individuals affected by making quarterly estimated tax payments on September 15th and January 16th now have until January 31st to file tax returns and pay taxes that were during those times. 

Vehicle Titling and Registration Requirements Suspended 

Texas residents in counties impacted by Hurricane Harvey will not have to worry about vehicle titling and registration requirements for the next 45 days. Governor Greg Abbott suspended certain statutes related to the enforcement of title and registration laws in the 58 counties included in the state’s disaster declaration. 

Customer Inquiries to the OCCC

We are working closely with the Office of the Consumer Credit Commissioner to help them process questions received from customers efficiently. Every CAB transaction contract, and most disclosures, include the name, telephone number, and the email address of the OCCC. 

Every time a consumer makes a complaint to the OCCC, the agency is required to open a file, contact the consumer, contact the CAB/lender, make a determination about a resolution for the complaint, and notify both parties in writing before closing the file.

However, after natural disasters, the agency typically receives questions from consumers in addition to complaints. If your company would like to designate a point person to address questions the OCCC may receive from your customers, please let me know. 

We will give the OCCC the name, telephone number and email address of your designee so the OCCC can refer questions directly to you. We want to give the OCCC every incentive to treat as many inquiries as questions, and not complaints (and staff prefers to open as few complaint files as possible). 

Texas Association of Business Hotline

TAB has established a hotline for businesses to connect to the resources they need as rebuilding begins. The hotline number is 512-637-7714. The hotline is available to all businesses. It is not limited to TAB members. You can also sign up to provide services as rebuilding begins in southeast Texas. For more information, visit: www.texbiz.org/2017/08/25/hurricane-harvey/.”

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

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The Texas Payday Loan Ordinance suffers another blow, this time Abilene voted it down.

The Texas Payday Loan Ordinance suffers another blow, this time Abilene voted it down.

by The CAB Man Texas on May 12, 2017

Down goes another “payday down city ordinance! On Thursday, April 27th. 2017 the Abilene City Council did right thing and voted “NO” on the so-called “payday loan city ordinance.”

Things do not seem to be going very well for the payday loan city ordinance these days the truth is really starting to get out that it is not even being enforced and the courts have decided (in two separate cases) that it is pre-empted by State Law!

So, let’s talk about how this latest defeat of the payday loan city ordinance went down in Abilene.  First, I must say that I have been to many city council meetings to participate in the payday loan ordinance conversation and I have never seen so many customers turn out to tell a city council to stay out of their personal finance decisions.  Not only did they turn out in droves to the meetings but those who could not attend inundated the city council email in-boxes and phone lines with a strong voice saying – vote “NO” on the ordinance.

Dozens of customers attended both the city council meetings the week of the “NO” vote wearing white t-shirts with “Stop the Ordinance” on it, inside the shape of a big red stop sign.  Supporters of the ordinance had to have been very impressed by the sea of white t-shirts streaming into the council chambers while cameras were rolling.  I think there was a grand total of (1) customer who attended the meetings that supported the ordinance on the other hand.  But, our anti-ordinance customers stood tall and proud when they approached the microphone.  Nearly (30) anti-ordinance supporters attended in their “Stop the Ordinance” gear, and the total for the two meetings had to have been way above that.

Those payday and auto title loan borrowers in attendance were there to tell the council to vote “NO,” to share their reasons for borrowing, and to vent their frustration that they could be possibly have their financial choices severely damaged by a reckless city ordinance that is a complete failure in 41 other cities in Texas.  In the end, it was the voice of those customers that stood proud and tall to defend themselves that swayed the city council to refuse to pass the ordinance.  I can remember the moment Councilman Shane Price held up the stack of comments he received and printed out from his email.  The vote “NO” stack was inches thick and the stack of comments from those who supported the ordinance was quite light.  In the end, he said that is what mattered.

What an empowering experience for many of these folks to go down to the formal and intimidating City Hall and have their voice heard.  The customers stood strong in the face of Newspaper reporters, TV cameras, and the breathless consumer advocate groups who were there to insult them and suggest they were not intelligent enough to manage their own finances.

I could see how those supporting the ordinance began to place pressure on city council, how they began to burden the council with solving the much larger issue that is at the core of the need for short term small dollar loans.  That is the fact that many Americans simply do not have enough money saved to fall back on in the event of an emergency or other problem in life.  70% of Americans do not have over $1,000 in their bank account – this is the problem.  The supporters of the payday loan ordinance were trying to sell the council and get them to pass an ordinance that would raise payment amounts, close businesses, and do nothing to impact that core issue.

I was talking with a customer of ours at the meeting and we were joking and wondering if the next ordinance to be rolled out would restrict Whataburger from selling hamburgers with meat in them so the Abilene City Council can end all heart attacks in city limits. Can you imagine this?

“Hey, Whataburger, yeah, we are not saying we want to put you out of business, but um, yeah we can’t allow you to actually put meat on your burgers anymore, because, you know, it uh, causes heart attacks and you are a terrible person too by the way, but we just want to protect our citizens from your predatory burger making practices with some thoughtful restrictions on fast food hamburgers…oh and burgers can still be sold at real restaurants though, they can still sell hamburgers it is just your kind of hamburgers that we don’t like, yeahhh.” 

It was hilarious, but quite honestly from our standpoint the payday loan ordinance is just as absurd.  The payday loan ordinance is a misguided disaster that is going to continue to unravel.  What the consumer advocate groups and church groups cannot grasp is the fact that the city ordinance does not achieve what they say they want.  It is a gigantic lie that has been perpetrated in 41 cities.  Their (mostly Texas Municipal League and Texas Appleseed) technique to get the ordinances passed has worked in those cities where council members do not do their homework, believe in a lot of regulation, or just want the businesses to go away.  But, their tired argument has grown stale, the final blow appears to be that cities are losing court cases over it, and cities are now voting it down.

Consumer advocates and church groups have their hearts in the right place but are choosing wrong vehicle to help solve what is a much larger problem than the short term small dollar loan industry.  I mean, unless you just did not do the math on how the 25% rule in the ordinance works, how can you ask the city council to approve an ordinance that will raise a borrower’s payment amount?  That fact alone should have caused the ordinances to get dumped in the trashcan two minutes after Texas Appleseed comes strolling into a city council person’s office.

Texas Appleseed – did you know payday transactions have hovered at the same level statewide even with a 41% decrease in stores?  Is the ordinance really the ideal vehicle for your cause?  If you want to do some more good, why not help communities apply for for a $30,000 grant from the Texas Educational Endowment Fund (http://occc.texas.gov/consumers/texas-financial-education-endowment-tfee-grant-program) to start financial education in the schools in your town instead?  This fund is completely funded by Credit Access Businesses to the tune of $400,000 per year (roughly).

The bad news regarding the TFEE is that Texas Appleseed and TML’s efforts resulted in the closure of 1,400+ locations which caused contributions to the TFEE to fall through the floor.  In 2013, the annual contribution amount was more like $700,000 per year.  $300,000 less per year is an insane amount of money that they took away from some groups that could have made a difference for the same people you are trying to help.

Also, the OCCC has taken a huge hit on licensing revenue that they could have used to hire new examiners to enforce the regulations already in place statewide.  Licensing fees are $600 per year per location, with 1,400 less locations in 2017 versus 2013 that comes to $840,000 less in licensing revenue per year.

Between the loss in TFEE contributions and the loss of OCCC licensing revenue that adds up to millions of dollars you have caused to evaporate from places that could have helped the consumers you are trying to protect.

To Churches and other groups besides TML and Texas Appleseed that have chosen to pile onto this issue when the issue comes up at city council meetings – why not just payoff all the loans that people take out with your own money?  Or why not just offer them a loan at 10% APR yourselves?  Stop asking the city fix the problem with a lousy ordinance and fund some loans yourself!

Long blog and I could go on about this for days, but I am going to wrap this up and save my energy for the next city that wants to look at the payday loan city ordinance.  I will conclude with another thank you to all the people that worked hard in Abilene to get the “NO” vote and again say how much we appreciated the opportunity to tell our side of the story to a city council who really committed to doing their research on this issue.

If you would like to read about what happened in Abilene here are a couple links to news on the “NO” vote that we were so thankful for:

http://www.reporternews.com/story/news/local/2017/04/25/payday-loan-debate-rages-abilene-city-council/100906592/

http://www.ktxs.com/news/citizens-voice-opinion-about-payday-lending-ordinance/449890488

http://www.bigcountryhomepage.com/news/abilene-city-council-rejects-regulating-payday-loan-businesses/700635585

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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Michael Brown takes the helm at TOFSC!

Michael Brown takes the helm at TOFSC!

by The CAB Man Texas on June 3, 2014

As of June 1, 2014 Michael Brown of CAB Consulting will be managing TOFSC         (http://tofsc.org/) and will no doubt be taking the organization to new heights!

The transition in ownership started mid-May and will run through June. Michael and Clay Chancey are working closely with one another to assure a smooth transition.

The future is bright for TOFSC! The organization will continue to communicate developments in the industry on a frequent basis, and it will also continue providing a platform for Texas CABs to interact with one another. Under new guidance, TOFSC will shape itself by listening to the needs of members, and by promoting concepts that will be aimed at their bottom line.

TOFSC areas of focus moving forward:

  • Increase membership and mobilize the group.
  • Provide frequent and meaningful communication.
  • Discuss innovative ideas and trends.
  • Surviving City Ordinances.
  • Increase communication with the OCCC.
  • Open forums and CAB Q&A sessions.
  • 2015 Texas Legislative session preparedness.
  • Community involvement.
  • CFPB Communications and Developments.
  • Vendors you need to know about.
  • Strategic Partnerships.
  • Capital and Third Party Lenders.

Please contact Michael with all questions or comments! He can be reached at 214-293-8676, or via email at: Michael@CreditAccessBusiness.com.

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What is the CFPB? Have you heard about it?

What is the CFPB? Have you heard about it?

by The CAB Man Texas on January 24, 2012

CFPB Basics

If you have not already, many of you may begin to hear about the “CFPB.”  The “CPFB” stands for Consumer Financial Protection Bureau.  This is a federal agency that was created in the aftermath of the US Economic Meltdown in 2008-2009.  The government felt that it was necessary to create this new bureau to monitor a broad range of businesses that contributed to the problem by not behaving in an appropriate manner, violating the law, or taking advantage of consumers.

“The central mission of the Consumer Financial Protection Bureau (CFPB) is to make markets for consumer financial products and services work for Americans — whether they are applying for a mortgage, choosing among credit cards, or using any number of other consumer financial products.”The 3 priorities of the CFPB will to be Educate, Enforce, and Study.”

The scope of the CFPB will include the Payday Loan and Auto Title Loan industries.  It is a possibility that our industry will be faced with regulations on local, state, and federal levels.  The CFPB held a field meeting in Birmingham last week and has released an “Examination Procedures”document that illustrates how they plan to go about reviewing industry businesses.

If you would like to review the Examination Procedures document, it is available online, or you may request a copy from CAB Consulting and Brokerage.  Also, if you would like to view an intro to the Field Meeting last week, you can do so here: http://www.consumerfinance.gov/getting-a-complete-picture-of-the-payday-market/

Right now we are all focused on getting our new CABs off the ground and implementing new notices and disclosures.  Set your sights on the CFPB next quarter and take some time to become familiar with it.  CAB Consulting and Brokerage is gathering facts and will continue to provide information as it becomes available.

If you have questions, please feel free to call Michael Brown at 214-293-8676, or email cabconbrokerage@gmail.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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Invitation to the OCCC Webinar on June 26th

Invitation to the OCCC Webinar on June 26th

by The CAB Man Texas on June 17, 2014

The OCCC sent out an invitation to Credit Access Business stakeholders today to a Webinar titled “What is a Credit Access Business?”  CAB Consulting has registered for the webinar and we look forward to attending on June 26th at 2pm CST.

Here are some of the topics that will be covered:

– Review of Licensing Requirements
– Review of the CAB Structure
– Review of Required Forms and Disclosures
– Review of CAB Quarterly and Annual Reporting

If you are interested in participating in the webinar, here’s the link to the Registration Page:  https://www4.gotomeeting.com/register/835753311

Space is limited to 100 attendees so act quickly and get registered!

 

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Texas Credit Access Businesses are making major contributions to the Texas Financial Education Endowment “TFEE” Fund

Texas Credit Access Businesses are making major contributions to the Texas Financial Education Endowment “TFEE” Fund

by The CAB Man Texas on January 4, 2017

In an earlier blog the CAB license renewal deadline was addressed as it is coming on January 31st.  It is very much worth mentioning that each year when the CABs across Texas pay the renewal fee of $800 per location, that $200 of that goes to the Texas Financial Education Endowment Fund (http://www.tfee.texas.gov/).  It appears that 2,125 CAB licenses will be renewed this year and that comes to $425,000 in contributions to the fund!

In years past there have been as many as 3,500 CABs so that would have meant that $700,000 was contributed for that given year.  CABs have been contributing to the fund since the CAB law went into effect in 2012 so 2017 will be the 6th year.  CAB renewals fluctuate but it is safe to say that $2-$3 million has been put in to this fund by Texas Credit Access Businesses.

“The Texas Legislature established the Texas Financial Education Endowment (TFEE) to support statewide financial capability and consumer credit building activities and programs. The endowment is funded through assessments on each credit access businesses and is administered by the Finance Commission of Texas.”

This program is 100% funded by the licensed CAB operators in Texas.  As a group we should all be pleased to make contributions towards the kinds of programs that have been given grants through the fund.

One bit of irony worth mentioning is that many of the programs who have received money from CABs are located in cities where ordinances were passed.  Goodwill Industries has been strongly opposed to our industry however they gladly received $32,000 from us in Austin!  I have personally seen them testify at City Council meetings in support of the ordinance.  Their testimony is typical in that had a very narrow, negative, and uninformed set of talking points.  Not only does Goodwill support the city ordinances but they join the argument that CABs take advantage of low income citizens.  Well in the case of the $32,000 grant, they took money money from low income citizens.  And, the participated in a movement that caused businesses to close (about 1,300 across Texas), people to lose jobs (2 per store would be 2,600 jobs gone), and after all of that the rates in ordinance cities went up 12% because of burdensome regulation.  Less competition hurts the consumer, once again…

For more information on market changes related to ordinances please go to the OCCC’s website and review the MSA reports for the last several years: http://occc.texas.gov/publications/activity-reports#cab

As for the good news – Texas Credit Access Businesses should get more positive attention for the impact they have on programs that do good for others, see below for some of the grant recipients:

K-12 Financial Education & Capability:

Texas Council on Economic Education – $32,000.00

Financial Coaching:

Family Pathfinders Tarrant County – $32,000.00

Community Development Corporation of Brownsville – $32,000.00

Adult Financial Education & Capability:

Goodwill Industries of Central Texas, Inc., Austin – $32,000.00
Easter Seals of Greater Houston, Houston – $32,000.00
Texas State Affordable Housing Corporation, Statewide – $32,000.00
El Paso Credit Union, Inc., El Paso – $25,000.00
Family Service Association of San Antonio, Inc., San Antonio – $32,000.00

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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Interesting development on the subject of the so-called Payday Loan City Ordinance

Interesting development on the subject of the so-called Payday Loan City Ordinance

by The CAB Man Texas on April 19, 2019

The Austin American Statesman put out an article this week (Senate votes to limit city regulations on private businesses.”) that discussed two bills in the legislature that were about to be passed by the Senate.  The bills, SB 2486 and SB 2488, will limit local government control over private businesses.  It appears the bills are directly focused on employer issues like hiring practices and break times.  

After hearing some very familiar talking points that support the authority of State law over local ordinances, it stands to reason that the passage of bills like these could lead to better days for Credit Access Businesses offering payday loans, installment loans, and title loans in Texas. 

Of course, an Austin City Council Member testified at a hearing against one of the bills.  Greg Cesar said one of the bills “disgracefully” preempted local regulations.  Let me remind Councilman Cesar of what a disgrace the attempted enforcement of the Payday Loan City Ordinance has been for the City of Austin.  They have been involved in two lawsuits for 2+ years against Speedy Cash and Advance America.  It has been a back and forth legal battle that has consumed City of Austin resources for far too long and even with all that money and time spent, no victory for Austin.  I am sure the residents of Austin would rather have their tax dollars spent on more meaningful subjects.  That is the disgrace! 

Now that I got a good swipe in against the Austin City Council, I will get back to two strong talking points I saw used. Each of them can be used almost as a mirror image in the argument for preemption of the Payday Loan City Ordinance by existing Texas law.

“One comment dismissed concerns over water breaks and work environments, stating that the Occupational Safety and Health Administration already regulates workplace safety.”  (This is exactly the same scenario with Credit Access Businesses – we are already regulated by the Office of Consumer Credit Commissioner).

Senator Creighton said: “I believe in uniformity across the state for the applicant and also for the employer, and it should happen in this building.” (This really applies to any business in Texas with more than one location.  Operating Credit Access Businesses in a City with an Ordinance and one without an Ordinance causes operational confusion and customer inconvenience).

At this point I believe that many Cities in Texas no longer look at passing the Payday Loan Ordinance because they know if they pass it and enforce it they will be looking at allocating several years’ worth of time in lawsuits over it.  So that addresses the further spreading of the Ordinance.  In terms of rolling back existing Ordinances across Texas, perhaps there issome opportunity ahead where the passage of these two bills creates the precedent for leaders in our industry to get that done!

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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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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Notices and Disclosures for use in Credit Access Business Operations

Notices and Disclosures for use in Credit Access Business Operations

by The CAB Man Texas on December 20, 2011

In addition to the provisional license, last Friday the OCCC worked to get rules for the Notices and Disclosures approved.  The rules, referred to as “7 TAC 83.6001-7 TAC 83.6008,” define the many ways in which a Credit Access Business is required to disclose particular information to consumers regarding the potential loan they are about to apply for, or for the actual loan that consumers agree to.

There are procedural requirements that a Credit Access Business address the nature of the transaction and possible alternatives to this service before the customer completes an application.   Also, the customer must acknowledge they have received these disclosures.

Considerable time has been invested in the development of several documents the OCCC advises Credit Access Businesses to use that are compliant with the law, and accomplish the goals of House Bill 2592.  Focus groups have reviewed the documents, and feedback was provided that shaped the final versions.  In the future it is likely that continued feedback from focus groups will shape these “dynamic” documents in a way that makes sense to all Credit Access Business consumers and stakeholders.

According to the OCCC, there is only one other state in the U.S. that has something similar or nearly as comprehensive.  The process of collaboration between the OCCC and industry stakeholders appears to have resulted in an exceptional set of detailed disclosures, which should please lawmakers and consumer advocate groups.   Fair regulations were passed, and rules were developed to implement the new State of Texas laws.  This high level State government achievement in should be made note of at the local level.  Knowing that such thorough systems are in place, city governments can now move on to more important topics like job creation and budget balancing.

The documents, which focus on single and multi-payment payday and title loans, are available through the OCCC website.  CAB Consulting and Brokerage is also in possession of the documents.  We are distributing them to clients, building familiarity with their intent, and drawing clarity from a 15 page two column set of rules.

If you have questions or would like to discuss, please contact CAB Consulting and Brokerage at 214-293-8676, or via email at cabconbrokerage@gmail.com

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