Your 2025 Texas BHPH Compliance Checklist

Generic “compliance matters” articles don’t help when your dealership is staring at a Texas Office of Consumer Credit Commissioner (OCCC) exam request. Searchers type phrases like “BHPH compliance software Texas” or “auto dealer repo laws TX 2025” because they need exact cure periods, letter templates, and audit artifacts. This guide makes your Lone Star-specific checklist actionable so you can scale Buy Here Pay Here operations without running afoul of Chapter 348 or TxDMV requirements.

Texas has ~2,800 dealerships and the nation’s toughest mix of OCCC oversight, TxDMV eTAG controls, and county tax variations. The rules below focus on the three questions independent dealers ask every week: When can I repo, which letters are mandatory, and how do I prove I followed the timeline? Use these sections as the standard operating procedure you plug into DealerClick’s workflows.

The Repo Rulebook: Texas Days-to-Cure & Notice Timing

Texas Finance Code §348 and the Texas Business & Commerce Code apply to every retail installment contract written by a BHPH store. Regulators look for documented evidence that you granted the right-to-cure window, mailed notices on time, protected personal property, and produced a deficiency notice that mirrors §9.616. Use the timeline below when configuring automated tasks inside DealerClick:

Practical sequencing:
Day 0: installment due.
Day 10: late fee allowed + cure letter triggered.
Day 20: cure expires; send Notice of Acceleration and move account into pre-repo stage.
Repossession date: capture GPS hit, condition photos, and driver receipt.
Within 48 hours: auto-generate the Right to Redeem/Sale notice with the earliest sale date set ≥10 days out.
Post-sale: send deficiency explanation + updated ledger, then archive in your digital deal jacket.

When dealers fail audits, it is usually because someone skipped the Intent-to-Accelerate letter, reused a Florida template (missing Texas disclosures), or lost proof of mailing. Building those checkpoints in software keeps your team honest even during staff turnover.

The Software Safety Net: DealerClick Automates the Texas Workflow

DealerClick’s BHPH compliance engine was built to map each state’s quirks directly into your collections board. Here’s how Texas dealers apply it:

• State-aware templates: Configure the Intent-to-Accelerate, Right-to-Redeem, and deficiency notices once. DealerClick merges the correct chapter citations, redemption totals, and Spanish translations automatically so you never retype legal language.
• Certified mail + eDelivery tracking: Push letters to USPS Certified Mail or email/SMS (when allowed) directly from the customer record. Tracking numbers, proof-of-receipt, and delivery timestamps are stored alongside the account so you can satisfy an OCCC request in minutes.
• Repo stage automation: When an account hits 20 days past due, DealerClick reassigns tasks to your skip team, logs GPS pings, and schedules the post-repo letter deadlines so nobody books a sale before the 10-day window.
• OCCC exam readiness: Upload your surety bond, MVRIS license, insurance certificates, and quarterly call reports into the same workspace. DealerClick’s report builder exports the “Texas BHPH Compliance” packet (payment history, notices, property inventory) that examiners ask for.
• TxDMV & tax integrations: Because repos often trigger eTAG voids and county tax adjustments, the platform syncs with TxDMV webDEALER/eTAG, recalculates inventory tax, and keeps lien release dates aligned with the sale event.

When you combine those guardrails with automated reminders for OCCC license renewals (due each December 31) and the $25,000 surety bond, your compliance story stops depending on a single office manager.

Digital Deal Jackets Protect You Better Than Paper

Paper folders get lost, coffee-stained, or misfiled between lot locations. Digital storage is now a competitive advantage because:

• OCCC and TxDMV field offices increasingly run remote exams. If you can’t upload a PDF of the signed Notice of Intent to Accelerate within 20 days, you risk penalties. DealerClick keeps every signature, call log, and payment adjustment in one record so export takes seconds.
• Chapter 348 requires you to retain retail installment contracts, payment histories, and collection notes for at least four years after payoff. Cloud storage with access controls and retention tags proves you met that rule, while audit history logs show who opened or edited each file.
• Severe-weather events (hail, flood) routinely destroy physical files in Texas. Digital deal jackets synced to redundant data centers satisfy disaster-recovery expectations from insurers and lenders.
• Electronic Buyer's Guide, Buyers Order, and bilingual disclosures reduce human errors, and eSign audit trails defeat “he said, she said” disputes in CFPB or Attorney General complaints.

2025 Action Plan for Texas BHPH Dealers

1. Document your Texas compliance profile. List every license (TxDMV general distinguishing number, OCCC sales finance license, eTAG credential), renewal deadline, and responsible owner.
2. Codify the repo calendar. Use the timeline above to build DealerClick automations: day-10 cure letters, day-20 acceleration notices, 48-hour post-repo alerts, and 30-day deficiency reminders.
3. Centralize proofs. Require staff to upload certified mail receipts, GPS screenshots, property inventories, and auction bills of sale before closing a repo task.
4. Audit quarterly. Run DealerClick’s compliance dashboard to sample 10 accounts per location, verifying that every letter used the Texas template and that digital files match TxDMV updates.
5. Train forward. Add role-based training in DealerClick’s LMS covering 2024 FTC CARS Rule updates, Spanish language disclosures, and TxDMV eTAG security so 2025 hires start compliant on day one.

Conclusion

Texas rewards disciplined BHPH operators and punishes sloppy workflows. When you hard-code the state’s cure periods, notice language, and retention rules into DealerClick, you eliminate “I didn’t know” as an excuse, breeze through OCCC exams, and grow confidently into new Texas metros. Ready to see how BHPH compliance software tuned for Texas actually works in your stores? Let’s build your checklist together.

Frequently Asked Questions

What licenses and bonds do Texas BHPH dealers need in 2025?

You need a TxDMV General Distinguishing Number (dealer license), a Texas OCCC Motor Vehicle Sales Finance license for every location that carries paper (including BHPH contracts), and a $25,000 surety bond tied to that license. Renewals open August 1 each year and must be filed by December 31 to avoid late fees. Many dealers also maintain a DRT (Dealer Record of Title) or eTAG sub-user ID for each store and upload ownership/insurance documentation inside DealerClick for exam reference.

How long must I keep compliance documents in Texas?

Chapter 348 and 7 TAC §84.709 require you to retain retail installment contracts, payment histories, collection notes, repossession packets, and notices for at least four years after the final entry (payoff, charge-off, or deficiency). Because the OCCC can demand copies within 20 days, dealers rely on digital deal jackets—DealerClick automatically tags documents with retention clocks and keeps immutable audit logs so you can prove nothing was altered.