Trying to collect from someone in TX without having an active bond posted appears to be a violation of TFC392.101 for which you can claim statutory damages. On saying that, if you file suit or if you complain to the AG, the CA will simply post the bond. But I still think you would have violations if they make collection efforts (letters, phone calls) whilst not having an active bond posted. That's the way I'm reading it.
I've been reading through this thread and I see a couple of things which I think may need clarifying for future readers when utilizing TFC392 for validation purposes:
First, I think you should mention TFC392 in your simple DV request. I say "simple" because I really don't think you need to go into too much detail about what the law says. It should be something like "I request strict validation per Texas Finance Code, Chapter 392". It is not incumbent upon you to tell them what the law says but I do think you need to mention TFC392 for your request to be valid under that law.
Second, you shouldn't mention anything about "60 days right to cure" or anything about DTPA in your initial letter. From what I read, you can only give the 60 days right to cure once you actually have some violations and dollar amounts to claim. The whole process should go like this:
Write the CA demanding DV per TFC392--send it CMRRR--don't mention DTPA or 60 days right to cure coz it doesn't apply yet!
Wait until a few days after the 30th day from when your letter was signed for--you can really only account for the 30 days from the time they signed for your request up until their response (if any) is dated/postmarked
If they've gone over the 30 days, write them again (CMRRR) telling them they violated TFC392.202(b) and that they must cease collection efforts permanently and also adjust the TL's as you want (typically permanent removal). Per TFC392.202(c) this must be done within 5 business days
Monitor the time again, from date they signed allowing for weekends and holidays. Add an extra business day to be sure.
If they haven't removed the TL's after the 5th business day, write them again specifying the violations, the amount(s) you want and why, and now give them the 60 day right to cure per the DTPA. Advise them that if they don't cure then they (and the surety bonds) are liable to be claimed upon for up to treble the amount(s) you requested.
On point #5, it's important to note that you actually have to specify the actual violations in detail and give specific dollar amounts and explain those amounts (eg. "mental anguish", "lawyer fees", whatever). You should also give a time frame for them to settle with you. For your DTPA claim to be valid you need to give the potential defendant the 60 days to cure and specify the actual violations, give a dollar amount for each one, and explain what the dollar amount is for. That's why you can't mention the 60 day right to cure in your initial DV letter--because you probably don't have any violations under TFC392 yet, or, if you do, you probably want to see if they don't respond in the 30 days, etc. to rack up more.
Also send the 60 day right to cure letter to the surety bond issuer outlining the specifics of the claims!
Upon receiving your 60 day right to cure letter, the CA can either settle with you or ignore you. If they ignore you, you can file suit against them and their surety bond once the 60 days has passed. However, if the steps above are not followed (particularly Step #5), the defendant can ask for an automatic 60 day abatement of the case.
At least, this is the way I'm reading everything.
EDIT: Oh and I forgot to mention...in your communications (or even a lawsuit if you file one), never ever refer to yourself as a "consumer". Always refer to yourself as a "claimant". This is VERY important!! The DTPA by itself is for "consumers" and you as a debtor are not really a "consumer". However, for the "tie-in" purposes from other statutes such as TFC392, the DTPA specifically allows these tie-in's for "claimants" via those statutes. I believe a couple of courts erred due to confusion about the whole "consumer" thing.