Stephanie is president and publisher of insideARM.com and insidePatientFinance.com. Her varied background includes careers in live entertainment, aerospace manufacturing, Internet city guide publishing, and organizational consulting, prior to joining Kaulkin Ginsberg (the family firm) as COO in 2001. Stephanie became publisher of insideARM in 2007, and president in 2010. Anyone who knows Stephanie will immediately tell you that her passion is in organization. Literally – she loves a clean desk, a well-labeled closet, an elegant process, a useful spreadsheet. A former member of Vistage (www.vistage.com), she also loves to learn about topics like leadership and self improvement.
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The Consumer Financial Protection Bureau has been very busy lately, of course. Most of its attention seems to be focused on various sectors of the consumer finance industry. But the agency did recently reveal its intention to return some focus to the debt collection industry.
The CFPB has three advisory boards that steer its thinking on financial regulation: one that is comprised of consumer advocates (naturally) and two made up of small banking interests. There is no board for large financial institutions.
There is also no advisory board for other companies, like debt collection agencies. An article in the Washington Post partially explains why. But still: how can the industry gain credibility and influence when other similarly sized industries seem better positioned?
The biggest CFPB news of interest to the debt collection industry from the last two weeks includes a CFPB announcement that it plans to amass records on the financial behavior of more than 10 million Americans, and an address by Deputy Director Steve Antonakes to the American Bankers Association about rulemaking, supervision, and examination.
The FDCPA very loosely defines “harassment.” But a phrase used to define harassment — contacting a consumer “repeatedly or continuously” — isn’t defined at all. Yet this is the basis of many FDCPA claims made against ARM firms.
Why leave interpretation up to judges when Congress, or at least the CFPB, can define it?
The big news over the last two weeks at the Consumer Financial Protection Bureau (CFPB) was the announcement of enforcement actions against four mortgage insurers and the expansion of its Consumer Response Complaint Database. A public conversation has also begun about the cost of compliance.
There was a lot of activity associated with the CFPB over the last two weeks as the march continues through the maze of companies that comprise the web of the U.S. consumer finance market.
The Consumer Financial Protection Bureau (CFPB) report to Congress on the Fair Debt Collection Practices Act (FDCPA) detailed the seven actions taken by the Federal Trade Commission (FTC) against debt collectors under the FDCPA. What’s interesting to note is that none of the seven were known larger market participants, members of the group of roughly 175 collection agencies that will be actively supervised by the CFPB.
As I read the CFPB’s report on the Fair Debt Collection Practices Act (FDCPA), I had a thought about the importance of consumer education, but the futility of current efforts at it.
I’ve heard many collectors complain about the industry’s lack of lobbying power, the lack of a meaningful public relations initiative, and the lack of ability to defend against frivolous lawsuits. Perhaps the ARM industry should partner with other larger industries in the financial services space.
Late last month, Peggy Twohig, Team Lead for the CFPB’s Nonbank Supervision office, spoke to a group of over 140 senior leaders of large market participants in the debt collection industry at a regulatory Summit hosted by insideARM.com in Washington, D.C.
Twohig stressed that there is a focus on consistency in the examinations, and that that they are looking at collections holistically, beginning with the process of issuing credit, and what happens during first party collection efforts. As a part of this approach, the Bureau has already been addressing debt collection issues at banks, including how they interact with their third party debt collection agency network.