THE BLOG

06
Jul

Texas CAB, Credit Access Business, Credit Services Organization Loan Model

Why Use the Texas CAB/CSO Model to Lend Money to the Masses?

Texas CSO-CAB Lending Model

Texas CSO-CAB Lending Model

In the old n’ times lenders funding payday loans – nowadays often referred to as installment loan lenders –  in states not having specific payday loan “safe-harbor” legislation, lenders like Curo, Enova, Elevate, would partner with a state-chartered FDIC insured bank (Bank of Delaware is one example) in order to charge payday loan borrowers more than the maximum state usury rates allowed.

This was the case in Texas, Arkansas, Pennsylvania, New Jersey…  The payday loan company acted as a “marketer, a servicer and a processor for the bank. This loan model is referred to as the “bank-model.”  The “bank-model” was extremely popular for years and resulted in substantial profits for the companies utilizing it.

As an example, a dated study by the Texas Consumer Credit Commissioner estimated 1.81 million loans were made in Texas using the “bank-model.”  $626 million dollars were loaned.  The average loan was $338 with an average APR of 511%.

The Federal Deposit Insurance Corporation’s Revised Guidelines for Payday Lending, which took effect way back in July of 2005, adversely impacted those payday loan lenders using this “bank model” to export usury rates across state lines.  This edict forbids banks from providing payday loans to people who have had an outstanding payday loan from any lender for more than 3 months in the previous year.  The Revised Guidance limits the frequency of customer usage of payday loans and limits the period a consumer may have a payday loan outstanding from any lender to an aggregate of three months during the previous 12 month period.  Based on an average term of 15 days, this effectively limits the number of payday loans that may be made to any consumer to six during any 12 month period.  All payday loans made from any payday lender would count against this limit.

So in the state of Texas, and Ohio and a few others, the cunning payday loan operators conceived of employing the “Texas Credit Services Organization (CSO) / Texas Credit Access Business (CAB)” loan model.

Texas CAB-CSO-Credit Access Business

The Texas CAB/CSO Model Explained

By implementing this CSO Model, we payday loan/installment loan lenders can service the continuing, unabated consumer demand for our loan products while remaining profitable enough to earn a fair return on our investments, pay our employees a fair wage, pay our taxes and support our communities.

The bottom-line is demand for the payday loan/installment loan product has been clearly established.  The CAB/CSO model is on a firm foundation with specific case law to support it; it has already survived a federal court case.  Additionally, the CAB/CSO model can yield higher transaction fees and margins than the bank model or, as in the state of Texas, the “Regulated Lender” licensing model.

The multi-million dollar payday loan companies have spent millions of dollars in legal fees to research and refine the CSO/CAB model; follow their example.

Texas: Do you know just enough to be dangerous? Do you need an in-depth understanding of how the Texas CAB/CSO consumer loan model works? Are you wondering how the 3rd Party Lender fits into all this? Why it appears you must pay to lend your own money? How do you get licensed to offer loans in Texas? Do you need a 3rd Party Lender?

We’ve got you covered! Our newest Training Manual is our 88 page:

Texas CSO-CAB Lending Model

Texas CSO-CAB Lending Model

“Texas CSO/CAB Model & Analysis: the Credit Services Organization Ver. 10.0.”

Table of Contents

What is a CAB/CSO

How a CAB/CSO Works

Nuts & Bolts of 3rd Party Lender

Key CAB/CSO Characteristics

Why Use the CAB/CSO Model

Pros & Cons Regarding the CSO Model

Strategies for implementing the CAB/CSO Model

CSO/CAB Software Solutions

Advance America & the CSO Model

Payday Lenders Strike Back

Key Legal Authority

Typical CSO Documentation

Resources

A Typical Consumer Loan Agreement

Introduction

Key Characteristics

Key references

Basic Program Documents and Materials

10% loans under Texas Finance Code Chapter 302

Texas Credit Services Organization Act (Tex. Fin. Code Chapter 393) 

79th Texas Legislature, Regular Session

Texas Finance Commission Review

Texas Attorney General Review

Other Background Information

Developments in Other States

CREDIT SERVICES ORGANIZATION: TYPICAL AGREEMENT

TEXAS FINANCE CODE

Lovick versus RiteMoney LTD

You can get a PDF copy now! Immediate download available.


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29
Jun

Magic Numbers: Don’t be Misled by Payday Loan Statistics-Thomas Sowell

By: Jer Ayles. Thomas Sowell at the National Review wrote an interesting article about payday loans and the magic of numbers.

In it he wrote, “A common practice in making small loans of a few hundred dollars for a few weeks is to charge about $15 per hundred dollars lent. Politicians, the media, community activists, and miscellaneous other busybodies are able to transform these numbers into annual percentage charges of several hundred percent, thereby creating moral melodramas and demands that the government “do something” about such “abuses.” [So-called excessive profits?]

Mr. Sowell goes on to discuss the ramifications of the passage of anti-small dollar lending legislation in Oregon that reduced the maximum allowable usury rate to 36% resulting in the closure of Oregon small businesses, the misinterpretation of “numbers” by politicians and the media to achieve their wrongheaded goals and more. He ends with this, “In other words, numbers do not “speak for themselves.” Politicians, the media and others speak for them — very loudly, very cleverly, and often very wrongly.

He also wrote, “Not surprisingly, most of the small finance companies making payday loans in Oregon went out of business. But there are no statistics on how many low-income people turned to loan sharks, or had their electricity cut off, or had to do without their medicine.”

“This is just one of the many ways in which self-righteous busybodies leave havoc in their wake while going away feeling noble.”

How to Start a Consumer Loan Business: Installment lending, car title loan lending, payday loan lending, personal loan business

Click This Image for Some Light Reading 🙂 Over Your Weekend!

It’s an inciteful article. It’s entitled, “Magic Numbers, Don’t be misled by payday-loan statistics.” It’s short and concise; certainly worth a few minutes of our time!

Again, here’s a link to the Thomas Sowell piece in the National Review: “Magic Numbers Don’t be misled by payday-loan statistics.”

Jer@PaydayLoanUniversity.com

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27
Jun

Industry Conventions: Installment Lenders, Payday Loan Lenders & Car Title Loan Lenders

I receive a ton of calls and emails from folks either already in the business of lending money to consumers and small businesses or looking from the outside in while simultaneously salivating over our ROI’s.

Many ask where and when the industry conventions take place. So, if you are in the same boat, go here RESOURCES and scroll down to the last four or five listings to view upcoming events in the “Business of Lending Money to the Masses.”

 

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25
Jun

Personal Loan Payday Loan Kiosk Machine

The future of consumer small dollar lending? Automated kiosk machines and smart phone apps.

No doubt, there will be continued demand by consumers for immediate cash in their hand, but for B2C small dollar lenders to scale will require their investment in technology, apps, SAS, automated kiosk machines…

Today’s kiosks have the ability to:

  • Apply for a loan
  • Submit the application including identification scanning
  • Underwrite and score the consumer loan application
  • Approve/decline the consumer loan application
  • Consumer agreement to loan terms and Esignature
  • Enable the consumer to receive loan funding via an ACH, debit card, cash…
  • Process consumer payments via bank account, EFT, cash, gift card…

No need to lease a location, hire a multitude of employees, and on and on and on… Result? Profits.

The thing is, THE FUTURE IS HERE! Email TrihouseConsulting@gmail.com Subject: “KIOSK”

Loan Machines Here Today

Loan Machines Here Today

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20
Jun

8 New Deals Available: Small Dollar Lending, Investments & Opportunities

I have 8 new deals for your consideration today.

Buy/sell/invest in small dollar lending/SAS/Cannabis companies. (PS: If YOU have a “deal” reach out! See below)

In no particular order:

OPPORTUNITY 1:

  • Goal: Capital raise in order to fund additional consumer loans employing the State licensing loan model.
  • Investor(s) needed.
  • Small Mngt. Team has nearly 50 years combined experience.
  • Company has funded tens of millions of dollars of consumer installment loans during the past 18 years via stores and the Internet. Avg. consumer loan = $500.
  • Debt & equity capital infusions considered.

OPPORTUNITY 2:

  • Licensed New Mexico “Small Loan Company” Acquisition Opportunity
  • Brick & Mortar Retail Store Location Offering Installment Loans
  • As of May 2018:
    • Location in Albuquerque, New Mexico
    • Employee operated
    • Consumer Loan Term 6-12 months/ Max APR 175%
    • $85K portfolio
    • 500 past borrowers not active but in good standing for future loan transactions.
    • New NM rules in effect: Current portfolio is a majority of “Unsecured Installment Loan Rule of 78th.”
    • 5-year Gross Revenue History avg. $300K/month
  • Other Details of Interest:
    • Simple Interest Loans are no longer offered in NM due to new regulations effective January of 2018.
    • Meaning? Zero fear of potential new laws in foreseeable future; overcomes the proposed CFPB payday loan rule.
    • All Loans passed 2018 State of New Mexico “DFI” examination.
  • Asking Price: $150,000. 

OPPORTUNITY 3:

  • Need a bank – an ODFI – for your loan operation? Need ACH, debit and credit card processing? Tribe & State licensed welcomed. Easy on boarding process. Startups considered. ISO’s and brokers not welcome; no middlemen. You deal with the bank. No one has better rates!

OPPORTUNITY 4:

  • Entrepreneur with 20+ years title loan and check cashing experience seeking additional funding for Florida title loan, multi-store startup. Co-founder of original Florida Check Cashers Assoc. High-tech founder re-entering the B2C lending industry. Equity/debt relationship… Noteworthy why? Because the small dollar lending environment has become VERY positive in light of recent regulatory developments, CFPB changes, Fintech, the economy…

OPPORTUNITY 5:

  • 10+ loan stores available in the Greater Ontario Area operating under a variety of brands. Can be assimilated under one “umbrella.”

OPPORTUNITY 6:

  • CSO/CAB El Paso Texas. Buyout a partner who is ill? Possibilities are extensive. Locally owned. Survived city ordinances… Great opportunity to enter the #2 small dollar loan market in the world; Texas. 

OPPORTUNITY 7:

  • State-of-the-art, small dollar loan management/website builder SAS company with existing clients in the USA & Canada looking for a U.S representative for marketing, introductions, trade shows… Equity considered. Standout SAS loan software with recurring monthly revenue: MRR. 

CANNABIS OPPORTUNITY 8:

  • MANY of my readers have been with me since the early 2000’s when I launched this small dollar loan industry Newsletter.
  • RISK is in our blood! It’s the nature of lending $$$$$.
  • MANY of my readers, friends and ME, have begun investing in cannabis; the fastest growing industry in the world!. I’ve personally funded a few grow facilities, dispensaries and a test lab. I’m into cannabis banking solutions and CBD online credit/debit card processing as well.
  • REACH out if you need banking, ACH/Credit/Debit processing, have deals, an interest, or capital you want to put to work in the California marijuana space.

If you are SERIOUSLY interested in any of these opportunities:

  • Email Jer at TrihouseConsulting@gmail.com
  • TYPE: “OPPORTUNITY & the Number” in your email subject.
  • You must include your name & contact info in the Body of your email in order to receive details, investor documents, disclosures… ANY followup!

To forward this or read Online:

http://paydayloanindustryblog.com/8-new-deals-available-small-dollar-lending-investments-opportunities/

Finally, as I usually end these pieces: GO MAKE SOME MONEY! And do a little good while you’re at it!!

Jer – Trihouse Consulting 702-208-6736

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