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The Law Offices of Alan Abergel, P.C. (“LOAA”) represents crafted precious metal dealers and precious metals businesses in Texas in registration, regulatory compliance, transactional, and administrative matters.
Attorney Alan Abergel is licensed by both the State Bar of Texas and the State Bar of California.
Under Chapter 1956 of the Texas Occupations Code, a crafted precious metal dealer (CPMD) is a person engaged in the business of purchasing and selling precious metal items, excluding:
Coins
Bars
Commemorative medallions
Items purchased for 105% or more of scrap value
Unless an exemption applies, any person operating as a crafted precious metal dealer in Texas must register with the Office of Consumer Credit Commissioner (OCCC).
Certain exceptions and exclusions apply depending on the business model and transaction structure.
Texas crafted precious metal dealers are regulated by the OCCC and may also be subject to oversight by federal agencies, including:
The Federal Trade Commission (FTC)
The Financial Crimes Enforcement Network (FinCEN)
CPMDs may be subject to state and federal requirements relating to:
Registration and renewals
Transaction reporting
Recordkeeping
Anti-money laundering (AML) obligations
LOAA provides legal services to Texas crafted precious metal dealers, including:
Assistance with CPMD registration with the OCCC
Assistance with CPMD registration renewals
Regulatory compliance counseling under Texas and federal law
Representation in OCCC, FTC, and FinCEN
investigations, inspections, and audits
Legal opinions regarding whether CPMD registration is required for specific business models
Ongoing regulatory compliance advice for precious metals businesses
Precious metals dealers may be subject to federal AML and Bank Secrecy Act (BSA) obligations. LOAA assists CPMDs with:
Drafting AML compliance programs and policies
BSA compliance counseling
Risk-based compliance frameworks for precious metals transactions
Regulatory documentation and internal compliance procedures
LOAA represents CPMDs in regulatory matters involving:
FTC regulatory inquiries and enforcement actions
FinCEN compliance examinations and investigations
The firm advises CPMDs on compliance remediation, regulatory response planning, and enforcement risk mitigation.
LOAA provides registration, compliance, transactional, and administrative regulatory defense legal services to crafted precious metal dealers.
LOAA does not represent consumers. The firm represents only Texas crafted precious metal dealers and precious metals businesses.
“I engaged Alan to help me through the complexities of obtaining my Lenders License. He was very knowledgeable about the process and provided me with a high level of service. I worked quickly getting him all the information needed and he worked at my pace. He was responsive to e-mails and questions and followed up with the DFPI to make sure everything was filed correctly. I had read online that this process could take as long as 6 months however Alan completed the assignment in less than 3 I will be retaining his services in the future to ensure my company remains in compliance."
--Petroleum Realty Group Inc.
"I hired Alan to represent me as a mortgage broker before the California Department of Real Estate. I couldn't be more pleased with Alan's services from start to finish. Alan was clear and concise. Alan's communication throughout the process was professional. I received the results I hoped for. Thank you Alan. I'll definitely recommend you to ALL and use your services again in the future shall I need anything!"
-Anonymous
"Very helpful in assisting in obtaining an OCCC Texas Motor Vehicle Sales Finance License. Very knowledgeable in answering all questions the OCCC asked for on their questionnaire. Highly recommended and would re-hire for any future assistance regarding motor vehicle and finance business. God Bless!"
-Raul
