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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.
- September 12, 2023 - 1:30PMPastSeptember 8, 2023 - 11:00AMPastApril 26, 2023In 2016, a major US lender (“the Lender”) became the first company to use the Oliver platform to coordinate and supervise the law firms it hires to collect defaulted loans. Amid increased regulatory scrutiny of debt collection activities, the banking company, one of the nation’s five largest, was looking for a cost-effective way to ensure its entire litigation process complied with state and...December 1, 2022 - 2:00PMPastNovember 29, 2022 - 1:00PMPastAugust 1, 2022Ladies and Gentlemen: The American Bankers Association (ABA), Consumer Bankers Association, Credit Union National Association, and National Association of Federally‐Insured Credit Unions (collectively, Associations) welcome the opportunity to comment on the Consumer Financial Protection Bureau’s (Bureau) Advance Notice of Proposed Rulemaking (ANPR) regarding credit card late fees and late...