2024-Navigating the Texas Credit Access Business CAB & CSO: A Comprehensive Guide for CABs, CSOs, 3rd-Party Lenders, Regulators & Consumers

Posted by Team Jer / Texas, Texas CAB, Third Party Lender Texas

The personal lending landscape can be complex, filled with various regulations and guidelines that lenders must navigate.

Texas, known for its robust economic environment, is no exception.

One option available to lenders in Texas is to operate under the Credit Access Business (CAB) / Credit Services Organization (CSO) model with a 3rd-party lender.

This blog post aims to provide an overview of the CAB/CSO model, how it works, and the benefits it offers lenders and consumers in Texas.

Texas’s Credit Access Business (CAB, often referred to as a CSO) model, presents a highly attractive and lucrative venture for businesses seeking to enter or expand in the consumer lending industry.

With a streamlined pathway to regulatory compliance and a specialized role that mitigates various risks, the model offers strong foundational advantages.

The model is particularly lucrative due to the ability to charge high Annual Percentage Rates (APRs), often reaching the 400%+ range, significantly boosting profitability.

Additionally, the model provides CABs a competitive edge through niche specialization and agility in responding to market demands.

As intermediaries, CABs are uniquely positioned to offer services from customer acquisition to loan origination to servicing, creating an ecosystem that benefits the business and caters to diverse consumer needs.

In summary, the Texas CAB Model delivers a compelling business case featuring simplified regulatory processes, significant revenue generation through high APRs, and unique market advantages, setting up Credit Access Businesses for considerable business success.

What is the Texas Credit Access Business (CAB) Model?

The CAB Model is a framework for businesses to offer short-term, subprime personal loans.

In this model, a licensed Credit Access Business [CAB] is an intermediary between borrowers and a 3rd-Party Lender.

The CAB takes care of loan originations, underwriting, customer service, and the collection of payments, but it does not directly fund the loan. Instead, a third-party lender funds the loan. The third-party Lender is not required to secure a license.

Texas CAB: How Does It Work?

1. Customer Application: A borrower applies for a loan via the CAB’s website/storefront.

2. Third-Party Approval: The application is reviewed, and if approved, the loan is funded by the third-party Lender.

3. Loan Servicing: The CAB takes responsibility for the loan servicing, including communication, collection, and compliance.

4. Profit Sharing: The CAB and the third-party Lender share the profits based on an agreed-upon structure. [Discuss details with me.]

Licensing and Compliance

Before operating as a CAB, a business must obtain a license from the Office of Consumer Credit Commissioner (OCCC) in Texas. It’s essential to adhere to the guidelines and laws specified by the Texas State OCCC.

For 3rd-Party Lenders

Advantages for 3rd-Party Lenders in the Texas CAB Model: A Deeper Dive

The Texas Credit Access Business (CAB) model, which has seen increased adoption in the State of Texas, has a unique structure that involves a third-party lender providing the actual loan capital. This lending model has several advantages for the 3rd-party Lender, and it’s worth diving deeper into what makes this framework particularly enticing for lenders providing capital to a Texas CAB.

1. Superior Return on Investment [ROI]:

By operating under the Texas CAB model, 3rd-Party Lenders can achieve superior returns on their capital. 3rd-Party lender fees are collected by the CAB from consumers on behalf of the 3rd-Party Lender, thereby achieving 10% – 15%+ on their capital [Typically collateralized 1:1 by the Texas CAB! I have details.]

2. Market Expansion: Geographic and Market Expansion

By collaborating with a CAB, a 3rd-party lender can quickly expand its market reach within Texas without establishing a physical presence in the state. This quick-to-market approach allows for agile responses to market trends and consumer needs, creating more opportunities for revenue generation.

3. Lower Operational Overhead

In the Texas CAB model, the Credit Access Business oversees the operational aspects such as customer acquisition, loan application processing, underwriting, disbursement, and collections.

This means that the 3rd-party Lender can invest less in these areas, thus saving on operational costs.

They also avoid the need to maintain a customer-facing operation in Texas, which can be significant in terms of financial outlay and operational complexity.

4. No Need for a Separate License

One of the most immediate benefits for the 3rd-Party Lender is the regulatory relief that comes with not requiring a separate loan license from the Texas Office of Consumer Credit Commissioner (OCCC).

This is a significant advantage because obtaining and maintaining a license can be time-consuming and costly and subject lenders to audits.

The CAB takes on the responsibility of licensing and compliance, allowing the 3rd-party Lender to focus more on their core business operations.

5. Competitive Diversification

Being a 3rd-party lender to a Texas CAB allows a lender to diversify its product offerings.

This can be particularly valuable for lenders specializing in other types of loans and looking to diversify their portfolios without incurring high setup costs and compliance burdens.

Takeaways for 3rd-Party Lenders: The Texas CAB model with 3rd-party lending offers several compelling advantages for lenders who provide capital to Credit Access Businesses.

From reduced regulatory burdens to lower operational costs, risk mitigation, and favorable profit-sharing structures, the model can be an excellent avenue for 3rd-party lenders seeking to enter or expand in the Texas personal loan market.

Amplifying the Upside: Benefits for Credit Access Businesses (CABs) in Texas

For CABs

Operating as a Credit Access Business (CAB) in Texas, in partnership with a third-party lender, has several unique advantages. The CAB model offers numerous benefits for CABs’s from a specialized role in the lending ecosystem to specific profit opportunities.

Let’s delve deeper into why becoming a CAB in Texas can be a lucrative and strategic business decision.

Streamlined Regulatory Compliance & Facilitated Licensing

CABs are required to obtain a license from the Texas Office of Consumer Credit Commissioner (OCCC).

Once they get this license, they can act as an intermediary between borrowers and third-party lenders.

The licensing process for CABs is generally more streamlined than the stringent criteria that traditional lenders often have to meet.

Regulatory Expertise

As a specialized business, CABs often build up a wealth of expertise in navigating local and state regulations.

This makes compliance less cumbersome and allows the company to focus on growth and profitability.

Risk Mitigation

Diverse Portfolio

By collaborating with multiple third-party lenders, CABs can diversify their loan types, spreading their risk.

The impact of defaults on any single type of loan is thus reduced.

[NOTE: CABs who fail to collaborate with multiple 3rd-Party lenders for redundancy place their businesses at risk! Think of this strategy as you should for banking and payment processing!!]

Revenue Generation

Robust Revenue Potential via High APRs

Contrary to the misconception that the CAB model operates on thin margins, CABs in Texas often charge Annual Percentage Rates (APRs), reaching as high as 400%+.

This provides a significant revenue stream for CABs and, thus, a robust financial incentive to originate more loans.

Scalability and Profit

With such high APRs, the CAB model becomes exponentially profitable as the volume of originated loans increases.

Unlike traditional low-margin models, the CAB system in Texas allows for a more lucrative scaling strategy, where every additional loan originated adds significantly to the bottom line.

Impact on Revenue

Given the high APRs, even a modest volume of loans can generate substantial revenue >profits.

This aspect makes the business model extremely attractive for those who wish to enter the lending space without the overhead and risks associated with more traditional lending models.

Multiple Revenue Streams

CABs have multiple ways of generating income, including fees for providing ancillary services to borrowers and profit-sharing arrangements with third-party lenders. This results in a more stable and diversified revenue base.

Competitive Edge

Niche Specialization

CABs specialize in certain types of loans (e.g., short-term payday loans, installment loans, collateralized car title loans…) that traditional lenders don’t offer.

This creates a niche market where CABs can become the go-to option for borrowers.

Agility and Adaptability

CABs are more agile compared to traditional financial institutions.

They can quickly adapt to market changes, implement new technologies, and tailor their services to meet consumer demands, giving them a competitive edge.

Enhanced Customer Relationships

One-Stop Service

As an intermediary, CABs offer a one-stop service for borrowers, handling everything from application to loan servicing and even debt collection. This convenience can attract more customers and improve customer retention.

Local Market Expertise

Operating within Texas yields Texas CABs a strong understanding of local market needs and consumer behaviors, allowing them to tailor their products and services more effectively.

Takeaway for CABs

The Texas Credit Access Business model offers an array of benefits that can make it an appealing venture for businesses interested in the lending space.

From a more straightforward path to regulatory compliance and risk mitigation to diverse avenues for revenue generation and a competitive edge, the model sets up CABs for significant business advantages.

The Profit-Sharing Dynamics Between 3rd-Party Lenders and CABs in Texas

Texas’s Credit Access Business (CAB) model offers a unique and lucrative profit-sharing arrangement that mutually benefits both the CAB and the 3rd-party Lender.

This framework allows 3rd-party lenders to leverage the expertise and customer base of CABs while CABs benefit from the capital these lenders provide.

Let’s delve into how the profit-sharing mechanism typically works, focusing mainly on the 9.99% A, additional fees like NSF (Non-Sufficient Funds), and late fees that 3rd-party lenders may earn.

Risk and Reward Allocation

APR Distribution

In a typical arrangement, the 3rd-party Lender earns a 9.99% APR on the funds loaned to the consumer.

This APR is distinct from the higher APRs associated with CABs and serves as a stable, relatively low-risk revenue stream for the Lender.

Additional Fee Participation

In addition to the 9.99% APR, 3rd-party lenders often also share in other fees, such as NSF and late fees.

These fees can significantly boost the Lender’s profitability, especially when considered across a high volume of loans.

Revenue Collection by CABs

Efficiency and Expertise

CABs are responsible for collecting both the principal and interest payment and any NSF/late fees on behalf of the 3rd-party Lender.

The CAB’s established customer service and debt collection infrastructure ensures that these payments are collected efficiently, minimizing defaults and maximizing profitability.

Dual Benefit

While CABs do the legwork of collecting the fees, they are also vested in ensuring the collection process is efficient.

An effective collection process improves the CAB’s bottom line and incentivizes the 3rd-party Lender to continue partnering with the CAB.

Mutual Advantages in Profit-Sharing

Stable Revenue for 3rd-Party Lenders

The 9.99% APR and the additional fees offer 3rd-party lenders a stable and predictable income, which can be especially appealing given that CABs shoulder much of the operational workload and customer interaction.

Increased Capital for CABs

For CABs, the benefit lies in having access to the capital provided by 3rd-party lenders. [Reach out to Jer@TheBusinessOflending.com for details.]

This allows CABs to originate more loans and thus generate more revenue through their high APRs and service fees.

Enhanced Business Relationships

This profit-sharing arrangement fosters a healthy, long-term business relationship between 3rd-party lenders and CABs. It creates a symbiotic relationship where both entities profit while distributing operational responsibilities and risks.

The profit-sharing arrangement in the Texas CAB model provides a win-win scenario for both the CAB and the 3rd-party Lender.

With a reasonable APR of 9.99% and a share in additional fees like NSF and late fees, 3rd-party lenders enjoy a lucrative, low-risk revenue stream.

Meanwhile, CABs benefit from the operational efficiencies of this model and the ability to access more capital to originate loans.

Both parties, therefore, have strong incentives to maintain this collaborative and profitable relationship. [See me for details.]

For Consumers

Unpacking the Benefits for Consumers in the Texas CAB Model

The Credit Access Business (CAB) model in Texas provides many benefits for consumers.

Understanding these benefits can offer valuable insights into how this lending model positively impacts borrowers. Let’s dive deeper into each of these advantages:

Increased Access to Diverse Loan Products

Variety of Options

The CAB model often leads to a more diverse marketplace for loans.

Since the Credit Access Business acts as an intermediary and facilitator for multiple third-party lenders, borrowers get a more comprehensive array of loan products to choose from.

Whether you need a short-term loan to cover an emergency expense or a long-term loan for home improvement, the chances are high that you’ll find a loan product that meets your needs.

Catering to Different Credit Profiles

Because CABs may work with various third-party lenders, a broader spectrum of risk profiles can often be accommodated.

Borrowers with less-than-perfect credit histories will find loan products suited to their financial situations.

Streamlined Application Process

The CAB will offer a streamlined loan application process, where a single application can be used to apply for multiple loan products.

This saves time for consumers and increases the likelihood of finding a loan that best suits their financial needs.

Transparency and Consumer Protection

Regulatory Adherence

The CAB model operates under the purview of Texas state laws, which are crafted to protect consumers.

CABs must be licensed and regulated by the Office of Consumer Credit Commissioner (OCCC).

This ensures a certain level of compliance and standardization that safeguards consumers against fraudulent practices.

Clear Terms and Conditions

Another benefit of the CAB Model is its level of transparency to borrowers.

CABs must provide clear, concise, and transparent loan agreements [Try getting THAT from your local Stagecoach bank or credit union!], making it easier for borrowers to understand the terms and conditions, including interest rates, fees, and repayment options.

Informed Decision-Making

With transparent terms and the safety of state regulations, consumers can make more informed decisions.

Knowing the details upfront allows borrowers to more accurately assess the cost and affordability of a loan, reducing the risk of taking on unmanageable debt.

Enhanced Customer Service

Specialized Expertise

Since CABs specialize in subprime loan acquisition, underwriting, and servicing, their expertise in these areas is often higher than that of traditional lenders and banks.

This can translate to a smoother, more efficient customer experience from application to loan closure.

Personalized Service

Many CABs offer personalized loan servicing that includes prompt and proactive customer support.

Whether through easily accessible customer service lines, chat support, or in-person consultations, the focus is often on ensuring the consumer feels supported throughout the loan lifecycle.

Educational Resources

To add value to their services, some CABs also offer educational resources and tools to help borrowers understand loan management, budgeting, and financial planning.

This fosters a better customer relationship and empowers borrowers to make sound financial decisions.

Conclusion for Borrowers

For borrowers in Texas, the CAB model with third-party lending brings forth increased accessibility to a variety of loan products, enhanced transparency, and superior customer service.

These advantages contribute to a more consumer-friendly loan marketplace, enabling borrowers to manage their financial needs better.

In Closing

The Credit Access Business (CAB) model in Texas presents a compelling business opportunity in the lending arena for 3rd-Party lenders, consumers, regulators, and CABs.

Its distinct combination of robust revenue potential attributed to high APRs to offset the risks of lending to subprime borrowers having nowhere else to turn when faced with a sudden financial emergency, a streamlined approach to regulatory compliance, and its benefits to consumers make it attractive.

Add to this the inherent risk mitigation strategies and a keen understanding of local market dynamics, and it’s clear why the Texas CAB Model holds such allure.

For businesses aiming to capitalize on the lending space, the CAB model in Texas establishes a pathway to substantial profitability and superior ROI.

Want to be a cab?

A 3rd-Party Lender?

Do you know just enough to be dangerous?

Do you need an in-depth understanding of how the Texas CAB/CSO consumer loan model works?

Are you wondering how the 3rd Party Lender fits into all this?

Why it appears you must pay to lend your own money? How do you get licensed to offer loans in Texas? Do you need a 3rd Party Lender?

We’ve got you covered! We offer an 88-page “Texas CAB/CSO Small Dollar Loan Analysis” that thoroughly explains how you can enter the lucrative Texas market for lending to the masses.

The “3rd Party Lender rule can be difficult to grasp. Texas does NOT allow you to loan your own money. Weird, right?

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16
Jun

Supreme Court Rocks the Boat: Native American Tribe Lenders Subject to Bankruptcy Laws

Posted by Team Jer / Laws, Tribe

In the case of Lac du Flambeau Band of Lake Superior Chippewa Indians v. Coughlin, the Supreme Court ruled that Native American tribes are subject to bankruptcy laws like any other creditors.

Lac du Flambeau Band owns an online payday lending operation and argued that their sovereign immunity excluded them from an automatic stay of the Bankruptcy Code when a customer files for bankruptcy.

The Supreme Court, however, affirmed the lower courts’ decisions that such an exemption does not exist.

Justice Ketanji Brown Jackson, speaking for an 8-1 majority, asserted that a congressional statute only overrides sovereign immunity if Congress uses “unmistakably clear” language.

According to Jackson, the Bankruptcy Code satisfies this criterion as it unequivocally includes any and all government entities within its scope, including federally recognized tribes.

One point of contention was whether a federally recognized tribe qualifies as a “governmental unit.”

Jackson argued that the comprehensive nature of the definition of “governmental unit” within the Bankruptcy Code, which includes a broad range of governments of varying sizes and types and concludes with a catchall phrase that encompasses ‘other foreign or domestic governments,’ would naturally include such tribes.

An important part of Jackson’s argument was her interpretation of the phrase “foreign or domestic .”

She argued that pairing these two extremes indicates all-inclusiveness, providing examples like ‘rain or shine’ and ‘near and far.’

She contends that placing this pair at the end of an extensive list signals an intent to cover all forms of government.

Furthermore, Jackson reasoned that if enforcing regulatory authority during a bankruptcy or tax collection can be applied to governmental units, excluding certain governments from this definition would be inconsistent, particularly when these governments, like states and the federal government, also engage in tax and regulatory activities.

Given the governmental functions performed by federally recognized tribes, she concluded that the Bankruptcy Code also categorically applies to them.

Jackson dismissed arguments from the Band and dissenting Justice Gorsuch that the statute does not mention tribes explicitly, noting that the rule is not a “magic-words requirement” and doesn’t necessitate an explicit mention of Indian tribes.

She refuted Gorsuch’s claim of a rigid division between foreign and domestic governments, arguing that all governments fall somewhere on the spectrum between foreign and domestic.

The justices’ near-unanimity suggests a lack of willingness to twist the language of the Bankruptcy Code to exempt tribes from it, especially when such immunity is not granted to the states or the federal government.

Ready to learn more?

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11
Dec

Extreme Consumer Loan Business Profits?

Posted by Team Jer / Calif, Florida, Profits, Texas

Cash advance and payday loan businesses can offer superior returns for an entrepreneur focused on lending money to the masses.

Sure! We charge what are perceived to be high-interest rates because our customer acquisition costs and our default rates can be SCARY.

What to do? You simply build these metrics into your business plan.

You integrate with state-of-the-art customer acquisition channels, loan management software, and underwriting platforms.

The interest rates we charge enable us to offer the 60% of USA households living paycheck to paycheck access to money when faced with a sudden financial challenge.

Do you know that 38% of households earning $100,000/annually are living paycheck to paycheck as well?

In today’s economic environment, credit card companies are charging 29.95% APR. AND THEY HAVE LEVERAGE! Credit card companies report consumer payment history to the three major credit bureaus. We do not!

Cash advance, payday loan, installment loan and car title loan companies can be profitable. However, it is essential to note that the profitability of a payday loan/consumer loan business will vary depending on many factors, such as:

The amount of competition in the area.

The demographics of the area served.

Are you funding loans via the Internet, a brick-and-mortar or a “blended” model?

Internet-originated consumer personal loan defaults are generally double that of storefront locations.

The efficiency of the business’s operations. Meaning customer acquisition costs, underwriting costs, servicing costs, processing costs, and collections costs…

The overall state of the economy.

The state the consumer/borrower resides in.

Many states have regulations that limit the interest rates that payday loan businesses can charge, which will impact the business’s profitability.

For example, short-term consumer loan rates for borrowers residing in Florida are $10/$100 loaned. On the other hand, Texas is as much as $30/$100 loaned. California payday loans are $15/$100 loaned.

The ROI is strongly impacted by the types of loan products the Lender offers to the 60%+ of USA adults living paycheck to paycheck.

Personal loans
Car title loans
Installment loans
Amortized loans
Loans that depend on tips, accelerated ACH deposits
BNPL products that depend on merchant fees to earn a profit
Other

[A recent study revealed Buy-Now-Pay-Later [BNPL] companies are charging an average 380% APR when all the extra fees, tips, ACH acceleration fess… are computed!]

Achieving a 30% gross on your street money is typical. Many balance sheet lenders earn more. Many inefficient lenders earn less. As they say, “It depends!”

“Inflation Relief Price: $150.00

Our 500+ page Course: “How to Loan Money to the Masses Profitably.” Immediate PDF delivered to your Inbox.

19
Aug

Payday Loan License for Illinois

Posted by Team Jer / Illinois

Illinois Payday Lender License Application CheckList

Application Form
A copy of all organization documents is required to be filed with the Illinois Secretary of State and a copy of the filing of assumed business name with the appropriate County Clerk’s office if a sole proprietorship.
“Supplemental Application” as provided in the application packet and credit report of:
1. the proprietor, if the applicant is an individual
2. every partner, if the applicant is a partnership
3. the President, Secretary, Executive and Senior Vice Presidents, Directors, and individuals owning more than 25% of the corporate stock, if the applicant is a corporation; and
4. the manager, if the applicant is a limited liability company
Most recent year-end and quarter-end financial statements, or opening statements for new corporations, completed according to Generally Accepted Accounting Principals and certified by the original signature of the applicant, President, or manager of limited liability, or partner thereof. The balance sheet must contain only business-related items and demonstrate a net equity (total assets minus total liabilities) of $30,000.
Original $50,000 Surety Bond in favor of the Director of the Division of Financial Institutions, signed and sealed by the applicant and Attorney-in-Fact of the bonding company.
Appointment of Attorney-in-Fact for Service of Process
Photographs of both the inside and outside of the proposed location
Business Plan detailing the nature, amount, and term of loans to be made and types of security that will be taken
A list of all states where the applicant is licensed to issue Payday Loans. If the said license has been withdrawn, refused, canceled, or suspended in any other state, please state the specifics surrounding this event
Information Form as provided in the application packet
A check in the amount of $1000 forwarded to the Illinois Department of Financial and Professional Regulation to serve as a license fee. Fees are not refundable.
A request for authorization of any other business to be conducted at the licensed location
1. If requesting an Other Business Authorization, please forward a separate check to the Illinois Department of Financial and Professional Regulation in the amount of $100 per Other Business Authorization (OBA) requested. NOTE: Only one OBA is issued to a company to cover all licensed locations. This fee is non-refundable.

Example Illinois Payday Loan License

Please return the completed application and related fees to the address list below:

Illinois Department of Financial & Professional Regulation

Division of Financial Institutions

Consumer Credit Section

100 W. Randolph St. Suite 9-100

Chicago, IL 60601

Office Use Only

Log No.___________

Check #___________

Fee Slip__________

STATE OF ILLINOIS

DEPARTMENT OF FINANCIAL & PROFESSIONAL REGULATION

DIVISION OF FINANCIAL INSTITUTIONS

APPLICATION FOR PAYDAY LENDER LICENSE

PAYDAY LOAN REFORM ACT

Application is hereby made to the Director of Financial Institutions for a license to

engage in the business under the provisions of the Illinois Payday Loan Reform Act.

Full Name of Applicant:_______________________________________________

Proposed Licensed Location:________________________________________

(Address)

(City) (County) (State) (Zip Code)

Corporate Address:__________________________________________________________________

(City) (State) (Zip Code)

( ) 5. ( )_______________________________

Telephone # Fax #

Contact Person Federal Employer I.D. #

Type of Ownership: Sole Proprietorship , Partnership , Corporation , Limited Liability Company ,

Other____________________________________________________________________

If the entity is a corporation, State of Incorporation:______________________________________

Is applicant licensed to issue Payday Loans in any other State or Territory of the S.? ___________________

IF Yes, provide a list of the States.

At any time has the applicant entity listed above had its license cancelled or suspended in any other State or Territory of the S.? _____________________

If Yes, provide full details on a separate sheet.

At any time has the applicant ever had an application for a license to issue Payday Loans withdrawn or refused in any other State or Territory of the S.? ________________

If Yes, provide full details on a separate sheet.

If the entity is a foreign corporation, the date, and number of Charter in Illinois:

_________________

Date Number

Page 1 of 2

14.______ The Proposed site is not within one mile of a horse race track subject to the Illinois Horse Racing Act of 1975, within one mile of a facility at which gambling is conducted under the Riverboat Gambling Act, within one mile of the location at which a riverboat subject to the Riverboat Gambling Act docks, or within one mile of any State of Illinois or the United States military base or naval installation.

OR

______ The location was already in existence as a payday loan business as of June 1, 2005.

Does the applicant/entity maintain any other licenses issued by the Department of

Financial and Professional Regulation? ____________

If YES, please list type of license and license number:

Describe any other business that will be conducted at this location other than the business of making loans under the Payday Loan Reform Act.

under penalties of perjury, I declare that I have examined the application and all supporting documents submitted by me in connection therewith, and to the best of my knowledge, they are true, correct, and complete.

__________________

(Signature of Applicant) Date________

STATE OF ILLINOIS

DEPARTMENT OF FINANCIAL & PROFESSIONAL REGULATION

DIVISION OF FINANCIAL INSTITUTIONS

SUPPLEMENTAL APPLICATION PAYDAY LENDER LICENSE

All answers must be TYPED or legibly PRINTED. All questions must be answered.

Individual’s Name:_______________________________________________________________

(First) (Middle) (Last)

Corporate Title:_____________________________________

Percentage of Ownership:_____________

Date of Birth:_______________________

Social Security Number:__________________________________________________________

Business Address:________________________________________________________________

Resident Address:________________________________________________________________

Telephone Number:________________________________________________________________

Business Experience for past ten (10) years in descending chronological

Order: (A copy of a resume for the same period of time may be substituted

to satisfy this requirement.)

Years______________________________________________________________________________

From To Company Name:_________________________________________________________

Company Address:______________________________________________________________________

Position Held:________________________________________________________________________

Principal Duties:_____________________________________________________________________