We wanted to alert you to the attached informal guidance that has been issued by the Texas Finance Commission agencies, including the Texas Department of Banking, the Texas Department of Savings and Mortgage Lending, the Texas Office of Consumer Credit Commissioner, and the Texas Credit Union Department (the “Finance Commission Agencies”). The Finance Commission Agencies make clear this is INFORMAL GUIDANCE and reliance on such guidance does NOT provide any safe harbor to avoid potential civil litigation against any lender.
Please let us know if you have any questions regarding this information.
Full Memo: