Texas CABs: The Complaint Wave Is Here. Audit Your Disclosures Before Someone Does It For You.
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 […]
No Score. No Deal. No Logic: The Edge in Subprime Lending (What’s Working in 2026)
FICO Didn’t Decline Your Borrower. Your Data Stack Did. You didn’t lose that loan because the borrower was a bad bet. You lost it because your system had no way to see them. “No score. No deal.” That’s not a risk decision. That’s a data problem wearing a policy costume. Here’s the truth: FICO was […]
Employee Turnover Storefront Lending
Employee Turnover: The $50,000 Leak How employee turnover for both storefront and online lending quietly kills lending margins, and what operators who survive do differently. The Truth Most Operators Won’t Say Out Loud Lender employee turnover isn’t an HR problem. It’s a profit leak. Consumer lending employee retention is the metric that separates operators who […]
Best Practices for Underwriting Subprime Loans in 2026
Identity verification matters, but it is not underwriting. It only tells you the applicant exists. It does not tell you how they behave after funding. Real subprime underwriting looks at cashflow, volatility, repeat behavior, fraud signals, and timing. If your model begins and ends with ID, income, and a credit pull, you may be screening […]
The Fraud That Looks Like a Good Customer
Why first-party fraud is quietly eating portfolios while lenders keep chasing the wrong threat. Most lenders think fraud wears a mask. In subprime, it usually shows up with a driver’s license, a real bank account, and a payment history good enough to make you feel smart right before it punches a hole in your portfolio. […]
Free, Try My A.I. Clone for Subprime Lending Operators
Unveiling This Strategy: A Conversation With My A.I. Clone What you’re reading here came from a conversation between one of my clients and my A.I. clone. That is not a gimmick. That is the point. My clone is trained to break down complex lending questions into practical strategy, clear thinking, and real-world next steps. It […]
Subprime Lending KPIs That Tell You If You Are Actually Profitable
TL;DR: Most subprime lenders think they are profitable because they track the wrong numbers. The four KPIs that actually matter are charge-off rate by vintage, roll rate by loan type, cost per funded loan, and net yield after defaults. These numbers show whether your underwriting, collections, and unit economics are really working before the damage […]
The 36% APR Cap: What Actually Happens When You Pull the Ladder
TL;DR A 36% APR cap sounds like protection. It isn’t. The math doesn’t work at $4.15 in revenue on a $300 two-week loan. Lenders know it. So they leave. The borrower still has the emergency. The car still needs fixing. Tuesday still comes. They just have fewer legal options and more expensive illegal ones. You […]
Texas CAB CSO Licensing Update
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 […]