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The Texas Finance Code defines a property tax loan as follows: (2) "Property tax loan" means an advance of money: (A) in connection with a transfer of lien under Section 32.06, Tax Code, or a contract under Section 33.065, Tax Code; B) in connection with which the person making the transfer arranges for the payment, with a property owner's written consent, of property taxes and related closing costs on behalf of the property owner in accordance with Section 32.06, Tax Code; and (C) that is secured by a special lien against property transferred from a taxing unit to the property tax lender and which may be further by the lien or security interest created by a I deed of trust, security deed, or other security instrument. Tex. Finance Code $ 351.002(2). A property tax lender, in making such a loan, obtains a priority lien on the property. Id. at (2)(B); see also Tex. Tax Code $ 32.05(a) ("A tax lien on real property takes priority over a homestead interest in the property."). The average amount of a property tax loan is about $ 12,000. Ex. E (Property Tax Lending Consolidated Volume Report Calendar Year 2014). B. Property tax lenders' use of discount points leading to the adoption of 7 Tex. Admin. Code S 89.601(d)(1)-(6)