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Financial Services Law Insights and Observations

CFPB proposes delaying effective date for recent debt collection rules

Agency Rule-Making & Guidance CFPB Debt Collection Covid-19

Agency Rule-Making & Guidance

On April 7, the CFPB proposed to extend the effective date of two recent debt collection rules to allow affected parties additional time to comply due to the ongoing Covid-19 pandemic. The Notice of Proposed Rulemaking (NPRM) delays the effective date by 60 days of the two final rules issued under the FDCPA, which were scheduled to take effect on November 30 but are now proposed to take effect January 29, 2022. The proposed delay would give stakeholders affected by the pandemic more time to examine and implement the rules. As previously covered by InfoBytes, the first debt collection rule, issued in October 2020, addressed debt collection communications and prohibitions on harassment or abuse, false or misleading representations, and unfair practices. The second debt collection rule, issued in December 2020, clarified the information debt collectors must provide to consumers at the outset of collection communications and provided a model validation notice containing such information (covered by InfoBytes here).

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