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Financial Services Law Insights and Observations

Texas updates guidance for tax lenders, continuing to urge them to work with consumers and allowing employees to work remotely

State Issues Covid-19 Texas Lending Consumer Lending Licensing ESIGN Fintech

State Issues

On April 15, the Texas Office of the Consumer Credit Commissioner updated its advisory bulletin (previously discussed here, hereherehere, and here) urging property tax lenders to continue to work with consumers during the Covid-19 crisis. Among other measures, the regulator urges licensees to increase consumer communication regarding the effects of Covid-19 on the licensees’ business, work out modifications for payment difficulties, and review policies for fees, late fees, and delinquency practices, to help support successful repayment. 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 The guidance is in effect through May 31, 2021, unless withdrawn or revised.