Texas updates guidance for credit access businesses, continuing to urge them to work with consumers and allowing employees to work remotely

State Issues Covid-19 Texas Consumer Credit Licensing

On April 15, the Texas Office of the Consumer Credit Commissioner updated its advisory bulletin (as described here, here, here, here, here, and here) urging credit access businesses to continue to work with consumers during the Covid-19 crisis. Among other measures, the regulator asks licensees to increase consumer communication regarding the effects of Covid-19 on the business’ policies (including communication procedures), 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 The guidance is in effect through May 31, 2021, unless withdrawn or revised.