If you are a regulated lender licensed by the Texas Office of Consumer Credit Commissioner, something has changed in how you file your annual reports. Beginning March 1, 2026, the OCCC moved regulated lenders and property tax lenders off its old system and onto a new online reporting portal. If you have not updated your filing process, or if your CPA is still producing output formatted for the old ALECS system, you could run into problems when your annual report deadline arrives.
This guide explains what changed, what it means for your audited financial statements, and what you need to do now to make sure your next annual filing goes through without delays or administrative action.
Understanding the OCCC System Transition
Texas regulated lenders used to file annual reports through ALECS. That system is gone. The OCCC has moved to a new online reporting portal, and the transition happened whether you were ready for it or not.
Property tax lenders made the switch in May 2025. Regulated lenders under Chapter 342 followed between July and September 2025. As of March 1, 2026, annual reports must be filed through the new system. Other license types are rolling in through 2027.
One thing has not changed: the deadline. Miss it, and you are looking at administrative action and penalties. The portal is new. The consequences are not.
What Does the New System Require From Regulated Lenders?
The new system is not a simple upload. It requires you to complete structured schedules covering your balance sheet, net asset calculations, and loan activity, all organized in a format the portal can process.
One thing the system flags immediately is your net asset position. Texas law requires regulated lenders to maintain at least $25,000 in net assets. Fall below that, and you need to upload a justification document alongside your annual report. It does not replace your audited financial statements; it goes with them.
This is where your CPA’s audit for SML & OCCC matters the most. The numbers you enter into the portal need to match what your auditor prepared. If they do not, the OCCC will catch it.
What Changed for Your Audited Financial Statements?
The audit requirement itself has not changed. OCCC-regulated lenders under Chapter 342 still need annual audited financial statements prepared by an independent CPA in accordance with GAAP.
What changed is how those statements are used. Under ALECS, your annual report and your audit were largely separate processes. In the new system, the financial data from your audit needs to flow directly into the portal’s structured schedules. Your auditor has to understand how the new system categorizes assets, liabilities, and loan activity; otherwise, the output does not map cleanly, and you are doing manual reconciliation at filing time.
If your Texas CPA has not worked with OCCC-regulated lenders since the transition, that gap will show up when it is least convenient.
What Can Go Wrong With the New System?
Lenders who are not prepared for the new filing process are already running into a few common issues. Here is what to watch for:
- Data format mismatches. Audited financial statements prepared in a generic format may not map cleanly to the new portal’s schedule requirements, requiring manual reconciliation before you can file.
- Net asset calculation discrepancies. If your CPA’s net asset methodology differs from what the OCCC’s new system expects, your report may flag a deficiency even when your financials are healthy.
- System learning curve delays. First-time users of the new portal are taking longer to complete filings than expected. On a tight audit timeline, that extra time can push you past your statutory deadline.
- Justification document surprises. If your net assets fall below $25,000 and your CPA did not flag it in advance, gathering the right documentation after the fact adds days to your filing.
- CPA unfamiliarity with the new format. Not all CPA firms have updated their approach for the post-ALECS environment. Using one that has not creates unnecessary friction at filing time.
Documents to Have Ready Before You Start Your Annual Report Filing
- Audited financial statements for the applicable reporting period, including balance sheet, income statement, cash flow statement, and note disclosures
- Trial balance and general ledger supporting the audited figures
- Net asset calculation with supporting documentation, especially if you are near the $25,000 threshold
- Loan activity schedules broken down by loan type and volume as required by the new system’s reporting format
- NMLS Company ID confirmed and linked to your OCCC license record
- Prior year annual report for reference when completing comparative schedule data
- Justification document if your net assets fall below the required threshold
How to Choose a CPA Who Understands the New OCCC System?
Not every CPA who has previously worked with Texas regulated lenders has updated their process for the new annual report filing system. When you are evaluating auditors for your next engagement, ask these questions directly:
- Have you worked with OCCC-regulated lenders since the NMLS and annual report system transitions?
If the answer is no, they may be working from an outdated understanding of how your audit output needs to be structured. - Do you understand how the new OCCC portal schedules map to standard financial statement formats?
The answer should include specifics about balance sheet categorization and net asset reporting, not just a general yes. - How do you handle situations where a client’s net assets fall near the $25,000 threshold?
A CPA experienced with OCCC lenders will have a clear answer about how they document and present borderline net asset positions. - What is your turnaround time, and can you meet my annual report deadline? The OCCC does not grant extensions. Your CPA’s timeline needs to account for both the audit and any back-and-forth with the new portal.
- How responsive are you during the engagement?
When you are navigating a new filing system with a hard deadline, slow responses from your auditor are not an option.
Special Considerations for New OCCC License Applicants
New Chapter 342 applicants are entering under the new NMLS-based system from day one, so there is no transition to manage. That is one less thing to worry about, but new applicants have their own considerations.
Your license application requires financial statement documentation showing your net asset position. As a new entity, you likely do not have a full fiscal year to audit. Talk to your CPA early about whether an opening balance sheet, a compilation, or a full audit is what the OCCC actually needs at your stage. Getting that wrong delays your application.
One more thing worth knowing: the new annual report portal is the system you will use every year going forward. Getting familiar with it during the application process rather than at your first filing puts you ahead.
How Metwally CPA Helps New OCCC Applicants?
We work with new Chapter 342 applicants from the beginning, not just at audit time. We help you identify what financial documentation the OCCC needs at your stage of the application, whether that is an opening balance sheet, a compilation, or a full audit. We make sure your net asset position is documented correctly before you file, so your application does not come back with financial statement issues. And because we work with OCCC-regulated lenders on an ongoing basis, we know the new reporting portal and can help you understand what your first annual filing will look like before it arrives.
If you are applying for a new OCCC-regulated lender license and need a CPA who knows the process, contact Metwally CPA PLLC for a fixed-rate quote.
Frequently Asked Questions
Beginning March 1, 2026, regulated lenders and property tax lenders must file annual reports using OCCC’s new online reporting system. The old ALECS-based process is no longer used for these license types.
The core audit requirements under Chapter 342 have not changed; your financials still need to be prepared by an independent CPA in accordance with GAAP. What changed is how that data maps to the new portal’s structured schedules.
Failure to submit by the statutory deadline may result in administrative action by the OCCC, including assessment of penalties. No grace period has been indicated for the new system.
Texas regulated lenders under Chapter 342 must maintain at least $25,000 in net assets. If your audited financials show net assets below that threshold, the new system requires you to upload a justification document.
Possibly. If your CPA prepared reports under the old ALECS system, they should review the new portal’s schedule requirements to confirm their audit output format is still compatible.
Please note that while this information provides a general understanding of OCCC annual report filing requirements, it is recommended to consult with a licensed CPA for specific guidance related to your situation. If you have any questions, please contact us.
Get Your OCCC Annual Report Filed Right the First Time
Get Your OCCC Annual Report Filed Right the First Time. The OCCC’s new reporting system is not going back to ALECS. If your audit process and your annual report filing process are not aligned, that gap will show up at deadline time. Metwally CPA PLLC works with Texas OCCC-regulated lenders to prepare audited financial statements that map cleanly to the new reporting system’s requirements, so your annual filing is not a last-minute scramble.
Fixed-rate pricing. Digital delivery. Responsive turnaround so your OCCC deadline never slips.
Mohamed founded Metwally CPA PLLC in 2020 in the Dallas-Fort Worth metropolitan area. He holds active CPA license in the state of Texas and California. Mohamed is the firm’s Executive Director. Mohamed has a Master of Science (M.S.) degree in Accounting from University of Dallas. He has extensive assurance experience in a wide variety of industries, and he also devotes considerable time consulting and working with organizations and CPA firms on internal controls, audit quality, automation, and accounting best practices. He has over 15 years of audit experience.
Prior to founding the firm, Mohamed worked for big 4 and national firms for over than 10 years in the assurance practice. Mohamed worked on private clients as well as public clients and specialized in financial services sector.
He is a member of the Texas CPA Practice Issues, Diversity and Inclusion, and Governmental Accounting and Single Audits Conference Committees of Texas Society of CPAs.
Mohamed is a member of the American Institute of Certified Public Accountants, member of the AICPA small business group, member of the American institute of Certified Management Accountants, and Texas Society of Certified Public Accountants.
