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CBA responded to the CFPB’s Advanced Notice of Proposed Rulemaking (ANPR) on debt collections. In its notice, the Bureau cites it is the first agency with the authority to issue substantive rules under the Fair Debt Collection Practices Act (FDCPA), a law governing the practices of third-party collectors and debt buyers. The Bureau may address first-party debt collection activities under its unfair, deceptive and abusive practices (UDAAP) authority. The ANPR is the Bureau’s initial step towards issuing new rules regulating the relationship between creditors, third-party debt collectors and consumers.
- February 12, 2018Consumer Financial Protection Bureau Attention: Office of Financial Education 1700 G Street NW Washington, D.C. 20552 Re: Request for Information Regarding Consumers’ Experience with Free Access to Credit Scores Docket No. CFPB-2017-0037 82 FR 52284 (November 13, 2017) Dear Sir or Madam, The American Bankers Association  and Consumer Bankers Association  (collectively, the Associations) are...
- October 12, 2017On Thursday, October 12, 2017, the CFPB filed suit in federal court against the Federal Debt Assistance Association, LLC, and the Financial Document Assistance Administration, Inc., service providers from Baltimore, MD, for presenting themselves as affiliated in some way with the federal government. The CFPB also alleged the companies’ debt-validation programs violated the law by falsely...September 29, 2017CBA to CFPB: Help Banks Serve Consumers in Need of Short-Term Credit A huge segment of consumers are struggling to make ends meet in a given month – 43 percent to be exact – according to a new CFPB survey. Since the FDIC and OCC issued guidance essentially pushing banks out of the small-dollar lending market, consumers have been forced to use less-safe, less-regulated and more costly entities to...September 25, 2017September 13, 2017 VIA Electronic Submission Ms. Marlene H. Dortch, Secretary Federal Communications Commission 44 12 th Street SW Washington, D.C., 20554 Re: Reply Comments on Notice of Inquiry Regarding Call Authentication Trust Anchor, WC Docket No. 17-97. Dear Ms. Dortch, The Consumer Bankers Association (“CBA”)  appreciates the opportunity to respond to the Federal Communication...September 25, 2017September 22, 2017 VIA Electronic Submission Ms. Marlene H. Dortch, Secretary Federal Communications Commission 44 12 th Street SW Washington, D.C., 20554 Re: Reply Comments on Second Notice of Inquiry Regarding Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59. Dear Ms. Dortch, The Consumer Bankers Association (“CBA”)  appreciates the opportunity to respond to...September 18, 2017On Monday, September 18, 2017, the CFPB took action against the National Collegiate Student Loan Trusts and their debt collector, Transworld Systems, Inc., for alleged illegal student loan debt collection lawsuits. The companies sued consumers for private student loan debt the companies could not prove was owed, or debt too old to litigate. The lawsuits allegedly relied on the filing of false or...August 16, 2017Download “Collect More, Spend Less: An ROI Guide to Collecting Through Digital Channels” If your collections strategy is limited to predictive dialing, you could be wasting $4-$7 on each contact—and it’s not just because people are hanging up or not answering. Predictive dialers alone fail big because 93% of consumers prefer alternative channels such as email and text. By using more sophisticated...August 16, 2017The CFPB released two report this week outlining challenges with student loan repayment and repayment programs. The first report, entitled “ CFPB Data Point: Student Loan Repayment ,” found nearly half of student loan borrowers leave school owing at least $20,000 – double the share of borrowers a decade ago. The Bureau also found more borrowers are taking out student loans later in life, and...August 4, 2017August 4, 2017 By electronic delivery to: www.regulations.gov Darrin King Paperwork Reduction Act Officer Consumer Financial Protection Bureau 1275 First Street, N.E. Washington, D.C. 20002 RE: Information Collection Activities: Common Request [Docket No: CFPB-2017-0013] Dear Mr. King: The Consumer Bankers Association (“CBA”)  appreciates the opportunity to respond to the Consumer Financial...August 1, 2017Banks have invested billions of dollars into digital servicing capabilities in recent years. Yet, less investment and change has occurred within Collections and Default Management – outbound phone-based dialing and written communications are still the dominant strategies when customers become delinquent. There’s change on the horizon. Significant shifts in customer expectations, technology, and...