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Financial Services Law Insights and Observations

Texas Office of Consumer Credit updates guidance urging credit access businesses to work with borrowers

State Issues Covid-19 Texas Consumer Credit Licensing Repossession ESIGN

State Issues

On October 27, the Texas Office of the Consumer Credit Commissioner updated its advisory bulletin urging credit access businesses to work with consumers during the Covid-19 crisis (previously covered here, here, and here). Among other measures, the regulator urges licensees to increase consumer communication regarding the effects of Covid-19 for licensees, work out modifications for payment difficulties, and review policies for fees, late charges, delinquency practices, and repossessions. The guidance also: (i) reminds licensees of legal requirements for using electronic signatures, and (ii) continues to permit licensees to conduct activity from unlicensed locations, subject to certain conditions. The guidance is in effect through November 30, 2020, unless withdrawn or revised.

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