To the Texas Office of Consumer Credit Commissioner, Attention: Huffman Lewis
At the 2024 Texas Association of Pawn (TAP) Convention in Galveston, Texas, Mr. Lewis presented and addressed remote payments of pawn extensions. Mr. Lewis stated that pawn licensees may pass along the convenience fee to a consumer so long as the pawn licensee does not receive any fee, compensation, or reward.
Bravo Store System’s mobile application, MobilePawn, gives consumers the opportunity to make a payment conveniently from their mobile phone. The pawn licensee is not assessing the convenience fee to the customer, rather these fees are optional to the customer and are charged and collected by a third-party software provider.
The fees:
- Are not tied to the loan contract and should not be included in APR.
- Are not collected by the pawn licensee.
- Never hit a pawn licensee’s bank account.
- Are 100% optional to the customer.
The pawn licensee’s customers who take out loans have the option to make their payments in store. Alternatively, for the customer’s convenience, a pawn licensee who uses Bravo may offer consumers mobile payments which incur our third-party convenience fee. The fee is transparent to the customer making the payment, and the customer has the choice whether to pay the convenience fee or travel to the store to make their payment in person, without incurring any additional charges.
Sincerely,
Tally Mack
CEO
Bravo Store Systems