Monday, December 14 Eric Fancher and Huffman Lewis both of the Office of the Consumer Credit Commissioner [OCCC] conducted a highly informative, interactive workshop. This 6-hour session included many details involving oversight, the examination process, record keeping [including retention], what constitutes financing, the RISC, and repossessions.
As dealers we all want examination to go smoothly and quickly so Eric communicated that access to financed sales folders [open, paid, and repossessed] as well as customer account ledgers with proof of all transactions with the retail buyer goes along way towards ensuring compliance with application provision of the State Law.
BHPH dealers should have on file a completed RISC, Buyers Order, Credit Application, receipt of down payment, proof of payoff of a trade-in, Disclosure of Equity if trade-in, a notice to co-signer if applicable, and any other notice or disclosure signed by the retail buyer. There should also be an original Certificate of Title [or copy of title if pledged], Title Application receipt, Application for Texas