Texas CSO Credit Services Organization Transition to CAB Credit Access Business, January 1, 2012

If you have an interest in the Texas payday loan CSO Credit Services Organization transition to the new CAB Credit Access Business Model read on! Delete this now if not!!

Texas (CSO) Credit Service Organizations are facing a new phase of payday loan regulation as they are forced to transition to the Credit Access Business (CAB) model.

Texas has mandated several new requirements to obtain this new CAB license. As a result, many existing CSO’s are scrambling to make the January 1, 2012 deadline for implementation.

A new company called C.A.B Consulting & Brokerage, formed by a group of highly experienced payday loan executives (full disclosure: In addition to Michael Brown, Jer  with Trihouse is one of the founding members :o), is now available to help you with this transition!

C.A.B Consulting and Brokerage is the most informed consultancy in the payday loan – micro-lending space regarding the new Texas CAB laws. C.A.B.’s strategy is to focus exclusively on assisting existing CSO’s and new CAB’s through this transition. offers free information, packets, manuals, consultant arrangements and a Credit Access Business Blog. Contact C.A.B today to discuss options and transition services to move your business into this new era of lending in Texas. Sign up for the Newsletter via Email or an RSS feed for daily posts.

If you’re lending in Texas now, or you plan to enter the Texas micro-lending space, you need this new C.A.B. resource!

Michael Brown
Jer Ayles-Ayler
C.A.B. Consulting and Brokerage
“Compliance, Capital, and Collections”

Email Michael:
Call Michael: 214-293-8676
Fax Michael: 888-561-0986


Online Lenders Alliance OLA Convention Followup – Denver

Jer Ayles-AylerI just returned home from the payday loan Internet convention put on by OLA in Denver. My initial reaction?


I’ve been riding this payday loan roller coaster since 1997. From a legislative and regulatory perspective, it’s been challenging to say the least.

Our industry, the business of loaning money, has been attacked since time began. The thing is, DEMAND for our product cannot be legislated away.

There are some really smart guys in our space! And, we have trade organizations that leverage our individual strengths.

First we had FISCA. Then we had CFSA. And now we have OLA as well. All 3 are good organizations and all 3 deserve our support.

Over the next several days, I’ll address some of the latest techniques, solutions, technology and strategies for achieving success in the micro-lending space that OLA attendees were exposed to.

For now, like I always say, “Hang-in there payday loan fans because the future REALLY IS OURS!”


Bank Fees in Violation of Military Authorization Act?

One of the provisions of the FY 2007 Military Authorization Act, makes it illegal for creditors to grant payday loans and car title loans to military members.

The change also prohibits charging more than 36 percent interest to military borrowers. Fees, service charges, renewal charges, credit insurance premiums or any other product “sold” with the loan must be included when calculating the interest rate.

Among other things, this law prohibits “using a check or any other access to a member’s financial account as security for a loan.”

So… what if a member of the military has a checking account with one of the banks or credit unions making loans to customers based on their direct deposit paychecks? These “payday loans” are then repaid in full – both principal and fees – once the direct deposit clears. It’s VERY common for this bank customer to take out another loan. If you analyze the numbers, you soon calculate these bank customers pay $900 in interest to borrow $500 from the bank for less than 6 months – an APR of 365% !

Doesn’t this violate the Act? I’ve looked at these transactions and the banks and credit unions offer virtually zero disclosure. I’m not a lawyer but, if I was, “I’d be licking my chops!” The media is beginning to sniff this out. Both Bloomberg and The Wall Street Journal are on this. Bank of America and the other banks are getting nailed over this new $5 ATM fee. They’re about to get MORE HEAT! Man, what a shame.

What do you think?


OLA – Online Lenders Alliance Conference in Denver next week, read on

If you’re going to be at OLA – Online Lenders Alliance Conference in Denver next week, read on.

I can’t believe this is free!

Current Major Issues in Online Lending from the Regulatory, Litigation and Tax Perspectives Brunch

You’re invited to join Claudia Callaway and Christina Grigorian of Katten Muchin Rosenman LLP and Allen Kutchins and Tom Duffy of Kutchins, Robbins & Diamond Ltd. over brunch before the OLA Conference for an overview of the regulatory, litigation and tax issues facing online consumer lenders today.

If you have ANY interest in lending via the Internet or plan to, YOU NEED TO ATTEND! NO CHARGE!!

Monday October 10
10:00 AM – 12:00 Noon
Complimentary Brunch & Seminar

Sheraton Denver Downtown
Silver Room 1550 Court place

CFPB and FTC: New Rules, New Enforcement Actions

Offshore Lending: Tax Consequences and IRS Developments

Tribal Lending: A Primer

Tax Considerations for Your Corporate Structure

Litigation Roundup


Claudia Callaway
Allen Kutchins
Christina Grigorian
Thomas Duffy

These are some of the best minds in the payday loan Internet space! If you’re attending OLA you must attend.

Email Ann Jones   or call 202-625-3548  to get in! SPACE IS LIMITED!!