Consumer complaint received 2025-12-24 00:00:00
Product: Vehicle loan or lease — Loan
Issue: Repossession — Lender trying to repossess or disable the vehicle
Company: CCF Intermediate Holdings LLC
State: TX

Complaint narrative:
On XX/XX/XXXX, I entered into a title loan agreement ( Loan # XXXX ) with TitleMax of Texas , Inc. d/b/a TitleMax ( the " CSO '' ) and XXXX XXXX XXXX XXXX ( the `` Lender '' ) for my XXXX XXXX XXXX XXXX ( VIN : XXXX ). The agreement structured the transaction as a XXXX arrangement, charging a {$440.00} XXXX fee purportedly for credit services, separate from interest, resulting in a disclosed APR of 225.47 %. This setup appears designed to circumvent Texas usury laws, as TitleMax 's parent company, TMX Finance LLC, assumes full financial risk through guarantees and consolidates lenders as Variable Interest Entities ( VIEs ) per SEC Form 10-K filings, making TitleMax the true lender and the fee illegal interest.

At signing, I was not provided a completed copy of the loan agreement, violating Texas Finance Code 393.304 ( a ) ( 3 ) and TILA ( 15 U.S.C. 1638 ) disclosure requirements. The finance charge was misclassified, understating the true cost of credit.

Subsequently, in an undated prior incident, TitleMax repossessed my vehicle and demanded excessive redemption fees without an itemized notice, breaching Texas Finance Code 393.305 ( a ). I paid unspecified fees under duress to recover it, and TitleMax refinanced ( " loan flipping '' ) without new disclosures or a new agreement, violating Texas Finance Code 393.307. 

On XX/XX/XXXX, TitleMax agents attempted repossession at XXXX XXXX XXXX, XXXX XXXX, TX XXXX, lifting the vehicle while I was trapped insidea per se breach of peace under Texas UCC 9.609 ( b ) ( see XXXX XXXX TitleMax, XXXX XXXX XXXXXXXX XXXX XXXX XXXX XXXX XXXX  ] ). XXXX XXXX Police intervened ( XXXX XXXX ), halting the attempt. TitleMax now demands unlawful repossession fees without proper notice. 

These practices mirror TitleMax 's history of deceptive lending, as evidenced by CFPB enforcement actions : a XXXX {$9.00} XXXX fine for luring consumers into costly renewals and a XXXX {$10.00} XXXX penalty ( plus {$5.00} XXXX redress ) for unlawful title loans, overcharges, and violations involving sham structures. 

TitleMax 's actions have caused emotional distress, financial harm, and vehicle risks, constituting unfair, deceptive, and abusive practices under the Consumer Financial Protection Act. 

Desired Resolution Cancel the loan in full, release the lien on my vehicle, and refund all payments made ( {$440.00} XXXX fee plus any interest/fees ). 

Compensate me {$25000.00} for emotional distress, excessive fees, and depreciation. 

Cease all collection efforts and credit reporting. 

Investigate TitleMax 's XXXX model in Texas for systemic violations and provide redress to affected consumers. 



The case involves an allegedly predatory auto title loan from TitleMax of Texas , Inc., structured as a Credit Services Organization ( CSO ) to potentially evade usury caps, leading to claims of deceptive disclosures, unlawful repossession, and illegal fees. While Texas law permits high-interest title loans, the setup raises questions of true lender identity and compliance with federal and state regulations. 

Chronology of Key Events The following table outlines the timeline based on provided documents, highlighting alleged violations : Date/Period Event Alleged Violations Supporting Evidence XX/XX/XXXX Loan origination : {$440.00} CSO fee charged; 225.47 % APR disclosed ; no completed agreement provided at signing. 

TILA ( 15 U.S.C. 1638 ) : Misclassification of finance charge. Texas Finance Code 393.304 ( a ) ( 3 ) : Failure to provide contract copy.

Loan Agreement ( discloses APR but treats CSO fee as non-interest ) ; Statement of Claim ( asserts no copy provided ). 

Undated ( prior to XX/XX/XXXX ) Vehicle repossessed ; excessive redemption fees demanded without itemized notice ; refinanced without new disclosures ( " loan flipping '' ). 

Texas Finance Code 393.305 ( a ) : No redemption notice. 393.307 : No new agreement for refinancing. DTPA : Unconscionable conduct.

Statement of Claim and Original Petition ( describe events without specific date ) ; alleges duress payments. 

XX/XX/XXXX Repossession attempt : Vehicle lifted with claimant inside ; police intervened ( XXXX XXXX XXXX ). 

Texas UCC 9.609 ( b ) : Breach of peace ( per se with occupant inside, per XXXX v. TitleMax ). 

Statement of Claim ( cites incident and case law ) ; Original Petition ( details location and police halt ). 

XXXX XXXX, XXXX Demands for unlawful repossession fees without notice. 

Texas Finance Code 393.305 ( a ) : Failure to provide itemized redemption amounts.

Statement of Claim ( post-event demands noted ). 

XX/XX/XXXX XXXX requests served in JAMS arbitration ; no response. 

JAMS Rules ( non-compliance ) ; supports overall pattern of evasion.

Claimant 's First Request for Production ( lists 11 specific requests tied to claims ).

Analysis of Predatory Practices Title loans in Texas are regulated under Finance Code Chapter 393 for CSOs, allowing fees but capping interest at 10 % for lenders. However, the effective rate often exceeds 200 % when CSO fees are factored in, prompting scrutiny as potential usury. In this case, the 225.47 % APR stems from a {$440.00} CSO fee on a {$2600.00} amount financed, with the structure allegedly masking the true lender.

Evidence suggests integration : TMX Finance LLC 's SEC filings reveal full loan guarantees and VIE consolidation, indicating control over XXXX XXXX XXXX. This aligns with " true lender '' doctrines in cases like XXXX v. TitleMax ( XXXX XXXX XXXX. XXXX XXXX, XXXX. XXXX. XXXX ), where similar misdisclosures led to {$1.00} XXXX in XXXX penalties. 

Repossession issues compound the claims. The XX/XX/XXXX attempt violated breach of peace standards, as lifting an occupied vehicle is prohibited ( XXXX v. TitleMax, XXXX XXXX XXXX ). Prior and post-event fee demands without notices breach XXXX, echoing CFPB findings against TitleMax for unfair collections. 

CFPB 's history with TitleMax underscores patterns : XXXX action for deceptive renewals ( $ XXXX fine ) ; XXXX for unlawful loans to military ( $ XXXX penalty + $ XXXX redress ), including overcharges and hidden fees. A XXXX order addressed wrongful repossessions, mandating refunds for improper feesdirectly relevant here. 

Potential Remedies and Broader Implications Successful CFPB complaints often result in individual relief ( e.g., refunds, loan adjustments ) and contribute to enforcement. For instance, aggregated complaints fueled the XXXX TitleMax order, providing redress to over XXXX consumers. In Texas, parallel complaints to the XXXX or XXXX can amplify pressure, given state caps on title loan terms ( 180 days XXXX, XXXX renewals ). 

If unresolved, escalation to arbitration or court is viable, but CFPB intervention XXXX prompt voluntary resolution to avoid further penalties.

Company response to consumer: Closed with explanation