ATTN: Texas CAB Licensing Update – Transition to NMLS
Published February 27, 2026
Author: Jer
The Texas Office of Consumer Credit Commissioner (OCCC) has officially shut down Credit Access Business (CAB) functionality in the ALECS system as part of the transition to the Nationwide Multistate Licensing System & Registry (NMLS).
CABs will begin the official transition process Monday, March 16.
For now, you can go here to access licensing documents and guidance on the NMLS transition
A few important operational notes for the industry:
• If you were in the process of preparing a new CAB license application in ALECS but had not yet submitted it, those applications appear to have been deleted.
• If you currently have a CAB license application already under review, you will still be able to continue working through that application within ALECS.
• No new CAB license activity will be accepted in ALECS going forward.
Team Jer
TL;DR — Texas CAB Licensing Just Changed. Here’s What Matters.
ALECS is done. NMLS is your new licensing home.
March 16 is the hard start date for all new CAB applicants. Not a suggestion. Not a soft deadline. The date.
If you had an unsubmitted application in ALECS, it’s gone. Deleted when OCCC shut down CAB functionality. You’re starting over in NMLS.
If your application was already under review in ALECS, you’re fine. Keep working it. Don’t abandon it.
Existing licensees: this transition is not automatic. Four things need to happen on your end. Create your NMLS company account. Set up individual accounts for owners and control persons. Add your branch locations. Assign your branch managers. Nobody does this for you.
One question still doesn’t have an answer: what replaces ALECS for annual and quarterly CAB reporting. OCCC has not announced a replacement system. We’ll update this post the moment that changes.
Bottom line: if you’re a Texas CAB operator and you haven’t logged into NMLS yet, today is the day that changes.
The full breakdown, including step-by-step transition guidance and the FAQ operators are asking right now, is below.
Beginning March 16, all new CAB applicants will need to complete the entire licensing process through NMLS.
For existing CAB licensees, the transition application process will require several steps:
• Creation of an NMLS company account
• Creation of individual NMLS accounts for owners, control persons, and other required individuals
• Addition of branch locations (if applicable)
• Assignment of branch managers
Each of these steps involves its own process of data entry, document uploads, and attestations to properly link all company, individual, and branch records within NMLS.
Another notable change: OCCC reporting will no longer occur through ALECS. At this time it has not yet been announced what system will ultimately handle CAB annual and quarterly reporting going forward.
For many of us who have worked in Texas consumer lending for years, ALECS has been a simple — if sometimes quirky — system. We learned its nuances, its shortcuts, and its occasional roadblocks.
Now we begin working inside NMLS… which of course has its own set of complexities.
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Texas CAB / NMLS Transition: Questions Operators Are Actually Asking
Q: My new CAB application was in ALECS but I hadn’t hit submit yet. Is it gone?
Yes. Based on current information, those unsubmitted applications appear to have been deleted when OCCC shut down CAB functionality in ALECS. You’re starting over. The good news: you now start in NMLS, which is where this process lives going forward anyway.
Q: I have a CAB application already under review in ALECS. What happens to it?
You’re fine. Applications already under review continue through ALECS. Do not abandon it. Keep working it until OCCC closes it out or approves it.
Q: When does NMLS go live for new CAB applicants?
March 16, 2025. That’s the official start date. After that, all new CAB license activity runs through NMLS. ALECS is done accepting new submissions now.
Q: What does the NMLS transition actually require for existing licensees?
Four things, in order: Create your NMLS company account. Create individual accounts for owners, control persons, and any other required individuals. Add your branch locations if you have them. Assign branch managers to those locations.
Each step has its own data entry, document uploads, and attestations. It’s not complicated. It takes time. Start now, not March 15.
Q: Where do I find the official NMLS transition documents from OCCC?
Right here: Texas OCCC NMLS Transition Guidance. Bookmark it. Check it regularly. This is the primary source.
Q: What happens to annual and quarterly CAB reporting? ALECS handled that before.
Nobody knows yet. OCCC has not announced what system replaces ALECS for CAB reporting. This is the one open question in the transition. We’ll update this post the moment that information drops. Sign up for the newsletter if you want it delivered direct.
Q: Is NMLS harder to use than ALECS?
Different, not harder. ALECS was quirky but familiar. NMLS is more structured, more multi-layered, and used across dozens of states, so the interface reflects that scope. Give yourself time to learn it before a deadline is breathing down your neck.
Q: I’m brand new to Texas CAB licensing. Where do I even start?
Start with the eBook. It covers the full Texas CAB/CSO model, the 3rd-party lender structure, OCCC compliance requirements, and now the NMLS licensing process. Twenty-plus years of this industry, compressed into something you can actually run. Get it here.
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Q: Do I need a 3rd-party lender to operate as a Texas CAB?
Yes, and understanding why is half the battle. The Texas CAB/CSO model requires it. The eBook breaks this down completely, including how to find one, how the relationship works, and how to structure fees without getting sideways with OCCC.
Q: I’ve been operating in Texas for years. Do I really need to do anything right now?
If you’re an existing licensee: yes. The transition process requires action on your part, it’s not automatic. Create your NMLS company account. Get your individuals set up. If you have branches, add them. Do it before March 16, not after.
If you’re a new applicant: March 16 is your start date in NMLS. Use the time between now and then to gather your documents, understand the requirements, and not be surprised.