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Financial Services Law Insights and Observations

Texas Office of Consumer Credit updates guidance for regulated lenders

State Issues Covid-19 Texas Consumer Credit Consumer Finance Lending Mortgages Foreclosure ESIGN Auto Finance Fintech

State Issues

On August 20, the Texas Office of the Consumer Credit Commissioner issued updated guidance, previously covered here, for regulated lenders navigating the Covid-19 crisis. The guidance: (1) encourages lenders to work with consumers, including by working out modifications to assist with payments, waiving fees and charges, suspending charged-off accounts, and suspending repossessions of collateral or foreclosure of real property, among other things; (2) reminds lenders of legal requirements for using electronic signatures; and (3) permits lenders to conduct regulated lending activity from unlicensed locations, subject to certain conditions.  The guidance is in effect through September 30, 2020, unless withdrawn or revised.

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