Improving your Third Party Lender Arrangement
If you already are one, or if you are laying the groundwork for becoming a Credit Access Business in Texas, consider cementing your Third Party Lender component with more than a handshake. It goes without saying that we need to invest in proper consumer loan documentation and operating software. We should also do the same with our approach to the Third Party Lender relationship.
Now that the OCCC is closely examining many facets of the CAB as it operates, it is critical that you have a clear arrangement between your business and the Third Party Lender who issues loans through your CAB location.
Do you know that many CAB’s have written contracts which serve as the operating policy between them and the Third Party Lender? It is important that the CAB invests in this written company policy, and that it can be produced upon request. Do what you can to have a well rounded agreement in place as means to demonstrate your commitment to operating lawfully and fairly. Gain confidence in your readiness for an OCCC examination. Operating reports that echo your Third Party Lender Agreement are an intelligent addition to a well designed arrangement. CAB Consulting and Brokerage is working with licensed Credit Access Businesses and Third Party Lenders in Texas in these matters.
We can assist you in a review and improvement of your Third Party Lender arrangement. Feel free to contact Michael Brown at CAB Consulting and Brokerage at 214-293-8676 or cabconbrokerage@gmail.com to learn more.
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{ 2 comments… read them below or add one }
I am a chief general counsel (both contract and salaried) for a CAB operating in Texas. I am considering, and the CAB is willing if it is done correctly, to also be a lender to the CAB. Do you know any regulations, I cant seem to find any, that discuss what the nature of the relationship can not have as far as being independent. No authority on decision in business control matters….no authority on decision in who gets loans and who does not. Seems to me a properly drafted agreement would make all concerns disappear
Hello Kevin – that might be too close of a relationship being that you are employed by the CAB. You can always reach out to Sam Arora at Coats Rose Law Firm – they would be able to really dig in with you on the subject from a legal standpoint. Here is a link to his bio: http://www.coatsrose.com/attorneys/sumit-arora/
Very glad to see you visiting my site and would be happy to talk with you anytime my # is: 214-293-8676. Best – Michael B.