Debt Collection
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.
- November 2, 2021 - 12:00PMPastSeptember 30, 2021 - 2:00PMPastSeptember 21, 2021 - 1:00PMPastJune 8, 2021The 11th Circuit’s far-reaching decision in Hunstein v. Preferred Collection and Management Services, Inc. has created panic for those companies that fall within the FDCPA’s definition of “debt collector” and for the creditors that use them. Most back office teams are scrambling to operationalize worst case scenarios with passionate pleas to secure funding, hire-up and triage. If upheld, a third-...May 25, 2021 - 2:00PMPastMay 11, 2021Dear Speaker Pelosi and Leader McCarthy: On behalf of the undersigned organizations, we are writing to express our views on H.R. 2547, the “Comprehensive Debt Collection Improvement Act,” sponsored by Chairwoman Waters of the House Financial Services Committee. Collectively, our organizations represent a broad and diverse constituency of lenders, servicers, and additional market participants that...
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CBA Comment Letter re HR 2547 Comprehensive Debt Collection Improvement Act