Good afternoon Credit Access Business World! For those of you who are out and about on the internet today doing a little research on OCCC CAB Compliance, OCCC Audits, Credit Access Business licensing, etc, you most likely will happen upon this blog post. I have been working with Credit Access Businesses on their compliance, the OCCC quarterly reports, and examination preparation. Over the last few weeks there has been a definite up-tick in word on the street about the “Audit.” The OCCC is calling them “Examinations” and they began in mid-April.
I have been getting a look at the reports of clients across Texas who have gone through the process. If you have feedback to provide it would definitely be welcomed and passed on to other CAB’s so they can be prepared.
In December 2011, I met with the OCCC and was given some hi-lights of what an examination would be focused on. From what I am hearing, the OCCC is going further in the examinations than what I assumed after that meeting. My recommendation is that you focus on Chapter 393 of the Texas Finance Code, HB 2592, and HB 2594. Make sure your loan contracts include all recommended and required disclosures, and be ready to have files reviewed. Some CAB’s are being asked to refund some or all fees collected in 2012, so the price is high for non-compliance and sloppy documentation.
If you have doubts, there are many options out there, contact CAB Consulting and Brokerage, get with attorneys who are experienced, or reach out to friendly competitors. The small to mid-size operators might be in harm’s way as they are not traditionally the ones with consultants, on staff attorneys, etc. So if you are one who fits that profile – now is the time to invest in your business, take the time to do your research, or hire someone to review it.
If you are licensed you will be examined, and it is typical for the OCCC to simply show up at your store with no prior notice. Call Michael Brown at CAB Consulting and Brokerage, we can discuss options and get going on a plan. Michael can be reached at 214-293-8676, or via email at cabconbrokerage@gmail.com.
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