AFSA Provides Information to Texas OCCC on Motor Vehicle Recordkeeping

On January 16, AFSA submitted a comment letter to the Texas Office of Consumer Credit Commissioner (OCCC) regarding its notice of a January stakeholder meeting regarding the rules for motor vehicle recordkeeping.


In the notice, the OCCC requested more information regarding how licensees currently maintain motor vehicle records, including debt cancellation agreements and privacy notices. The OCCC also inquired about the cost of such recordkeeping and requested alternative methods for maintaining such records, other than a proposal to store full copies of each such document in a consumer’s file.


AFSA’s letter noted that most companies currently only retain the signature page of a debt cancellation agreement—the only unique page of the contract—and store an exemplar copy of each non-unique privacy notice sent to consumers. Following the stakeholder meeting and AFSA’s comment letter, the OCCC announced precomment draft rules allowing for alternative methods of recordkeeping incorporating the information provided in AFSA’s letter.


The precomment rules will be considered at the OCCC’s February 16 meeting. AFSA will continue to monitor the review process and keep members apprised of any future changes.