As you know, the Texas Sunset Commission is conducting a review of the Texas Department of Savings & Mortgage Lending, along with the Texas Department of Banking, Office of Consumer Credit Commissioner, and Finance Commission of Texas.
Sunset just released its report, recommending moving the Texas Department of Savings & Mortgage Lending into the Department of Banking. The full report may be found here.
As you can imagine, moving oversight of our business to the Department of Banking will bring our interests under the purview of an entirely new group of government bureaucrats, thereby negating the years of relationship-building we have cultivated with the Commissioner and agency staff. More importantly, under the Department of Banking, it is likely that much of our work and progress over the last three years—work that has resulted in minimal regulatory oversight—will be completely lost. The nuanced complexities of our business model could be ignored, since we will be treated and regulated in the same manner as Bank of America or Capital One.
Please review the full report and share any comments and concerns with the TLDA Executive Committee at your earliest convenience. The report will be presented in a public hearing sometime in the last part of May. Stay tuned for more updates and the official TLDA response to the report.