Texas Appleseed is back.
Ann Baddour’s Fair Financial Services Project has been gunning for payday and auto title lending for years.
If you’re surprised complaints are hitting CABs again, you haven’t been paying attention.
Here’s the truth: a complaint is an allegation, not a verdict.
But allegations still cost you time, money, focus, and operational bandwidth you don’t have.
The Texas OCCC has to take them.
They’re required by law to investigate whether jurisdiction applies and respond accordingly.
That machine starts moving whether you like it or not.
So stop reacting emotionally.
Start building a record.
What the law actually says.
Texas CABs operate under Chapter 393 of the Texas Finance Code and Title 7, Chapter 83 of the Texas Administrative Code.
That’s your playbook.
Not a consultant’s summary.
Not a trade group alert.
The actual rule text.
Here’s what most Texas CABs miss: the rule does NOT require your full fee table to be physically embedded on your homepage.
It says disclosures must be conspicuous.
It also expressly allows a direct-link approach; a clearly labeled link like “Fee Schedule” or “OCCC Notice” satisfies the requirement.
That’s a meaningful distinction.
But “conspicuous” means something.
Buried in a footer between your privacy policy and your ADA statement is not conspicuous.
One clear link at the top of your site, on your application page, on your social profiles?
That’s the standard.
Know the difference. Audit to the standard, not the spirit.
The disclosure timing problem.
This is where many Texas CABs are sloppy, and it’s avoidable.
Texas rules require disclosures to be provided before a credit application is presented and before a financial evaluation occurs.
Read that again. Before the application. Not after. Not during. Before.
In-store: Hand the disclosure to the consumer before you hand them a pen.
Online: the disclosure or a clear link to it belongs at the top of the application flow, before the consumer inputs anything meaningful.
If the customer has to hunt for cost information, you’ve already lost.
Fix it this week.
If a complaint lands on your desk.
Don’t rant. Don’t panic. Write a letter.
If the complaint is wrong, say it clearly.
Then prove it.
- Quote the controlling statute.
- Cite the exact TAC section.
- Then answer the allegation point by point:
- Screenshots of your website with dates and URLs.
- Photos of required in-store postings.
- Direct links showing where your fee schedule, OCCC notice, and consumer disclosures appear.
- Documentation of your application flow.
This is a record-building exercise, not a debate. Treat it that way.
The OCCC consumer assistance helpline is 800-538-1579. Call it if you need to. Document every conversation.
What to do this week.
Pull up Chapter 393 and 7 TAC Chapter 83 yourself. Read the controlling text, not a recap.
Walk every storefront.
Photograph every required posting.
Check every wall, counter, and point-of-sale area.
Audit every digital surface.
Your website, landing pages, application pages, and every social media profile.
Confirm that the fee schedule and OCCC notice are conspicuous and reachable in one clear click.
Move consumer disclosures earlier in your application flow. Before the form, not buried inside it.
Build a compliance binder now. Screenshots, URLs, timestamps, store photos. If you ever need to respond to a complaint, you want that file already built.
The bottom line.
You may be right. The complaints may be overreaching, politically motivated, or legally thin.
Doesn’t matter.
The winning move is not outrage.
The winning move is tighter disclosures, cleaner documentation, and a professionally written rebuttal that quotes the actual law and backs it with evidence.
If you’re clean, prove it. If you’re not, fix it.
This is operational awareness only, not legal advice. For specific situations, talk to your attorney.