AFSA Comments on Texas Finance Code October 30, 2019 AFSA’s State Government Affairs (SGA) team this week sent a comment letter to Texas Attorney General Ken Paxton in response to an opinion request from a state representative regarding the Texas Finance code. In the request, the representative asked the attorney general if a “credit services organization”, which is the state’s definition of payday and vehicle title lender, could extend forms of consumer credit beyond those explicitly authorized - namely deferred presentment or motor vehicle title loans. In the letter, AFSA strongly urged the attorney general to uphold the current interpretation of the Texas Finance Code, which maintains that credit services organizations should only be allowed to extend the forms of consumer credit that are explicitly authorized. Unlike credit services organizations, AFSA members are regulated and licensed by the Texas Office of Consumer Credit Commissioner. Altering the existing interpretation of the Texas Finance Code by allowing unregulated and unlicensed credit services organizations to extend other forms of consumer credit will open the door to an increase in predatory lending practices in Texas. This letter, as well as SGA’s other comment letters, are available in the direct advocacy section of the AFSA website.