"Key Points in the CFPB’s Outline of Proposed Rule for Third Party Debt Collectors" By Marshall T. Bell and Walter E. Zalenski (Consumer Finance Law Quarterly Report)
Consumer Finance Law Quarterly ReportMarshall T. Bell, Walter E. Zalenski
On July 28, 2016 the Bureau of Consumer Financial Protection (CFPB) announced that it is considering proposing a rule to “overhaul the debt collection market by capping collector contact attempts and by helping to ensure that companies collect the correct debt.” The CFPB released several related documents, including a report on thirdparty debt collection operations and an outline of the proposal (the Outline) to be presented to a panel of small businesses pursuant to the Small Business Regulatory Enforcement Fairness Act (SBREFA). Under the SBREFA process, the CFPB first seeks input from a panel of small businesses that likely will be subject to the forthcoming rule. A report regarding the input of those reviewers is then created and considered by the CFPB before issuing its proposed rule.
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Originally published in the Consumer Finance Law Quarterly Report; reprinted with permission.