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Essential Notices and Publications on Debt Collection from the Consumer Financial Protection Bureau

The Consumer Financial Protection Bureau (CFPB) is now the lead regulator of the ARM industry in the U.S. With expanded power from Congress, the CFPB is the first regulator to be given direct supervisory authority over collection agencies and debt buyers, including onsite examinations and business audits for larger companies. Regardless of size, every ARM firm will have to respond to and resolve each consumer complaint against it the CFPB receives.

The new regulatory dynamic was implemented fairly quickly and is now in full swing. Below are resources for ARM companies of all sizes. Please note that we update these documents regularly. If you have anything to suggest we add, please email

Other Important Debt Collection Documents from the CFPB

CFPB Outline of Proposed Rulemaking for Third-Party Debt Collection

The Consumer Financial Protection Bureau (CFPB) has released its long-awaited Outline of Proposed Rules governing third-party debt collectors. The proposal is 117 pages and covers a wide range of topics that had been raised nearly three years ago in the Advance Notice of Proposed Rulemaking. According to the Bureau, the proposed rules would — among other things — “overhaul the debt collection market by capping collector contact attempts and by helping to ensure that companies collect the correct debt.” The CFPB says they’ll “address consumer protection issues involving first-party debt collectors and creditors on a separate track,” saying that a second SBREFA outline and hearing is expected in the coming months. Topics covered in the outline include:

  • Debt substantiation
  • Transfer of data from collection agency to collection agency
  • Validation notices
  • Litigation disclosures
  • Time barred debt
  • Contact frequency and voicemail messages
  • Time, place, and manner of communication
  • Decedent debt
  • Consumer consent
  • Transfer of debt
  • Recordkeeping

CFPB Advance Notice of Proposed Rulemaking for Debt Collection

On November 6, 2013 the CFPB took the first step toward issuing new consumer protection rules for the debt collection market. Through its Advance Notice of Proposed Rulemaking (ANPR), the Bureau collected information on a wide array of issues. The 114 page document contains 162 questions about debt collection practices and the consumer experience. The comment period ended February 28, 2014. The the debt collection rulemaking schedule has since been updated twice, with the process now expected to extend into 2016.

For a high-level look into the comments from prominent industry and consumer groups, consider insideARM's report Assessing the Impact of CFPB Rules on Debt Collectors.

CFPB Monthly Complaint Reports

The Monthly Complaint Report uses a three-month rolling average, comparing the current average to the same period in the prior year where appropriate, to account for monthly and seasonal fluctuations. In some cases, the Bureau uses month-to-month comparisons to highlight more immediate trends. For the company-level complaint data, the Bureau uses a three-month rolling average of complaints sent to companies for response. This company-level complaint data lags other complaint data in this report by two months to reflect the 60 days companies have to respond to complaints, confirming a commercial relationship with the consumer. This is consistent with complaints found in the public Consumer Complaint Database.

CFPB Winter 2016 Supervisory Highlights Report

This tenth edition of Supervisory Highlights shows that the Bureau found violations in debt collection, consumer reporting, mortgage origination, remittances, student loan servicing, and fair lending. The report also shows that CFPB supervisory actions resulted in $14.3 million in relief to more than 228,000 consumers.

CFPB 2016 Annual Report on Fair Debt Collection Practices Act

Issued in March 2016, the is the latest of the annual FDCPA reports required by Congress. The report details enforcement actions, debt collection complaints, education and outreach, and supervision of collection agencies.

2015 Consumer Response Annual Report

Issued in March 2016, this is the CFPB's annual report analyzing the consumer complaint data received in the prior calendar year.

CFPB Ombudsman's Annual Report - Fiscal Year 2015

Published in December 2015, this is the most recent annual report from the Office of the CFPB's Ombudsman, an impartial advocate for a fair process between consumers, financial institutions, and the CFPB. The Ombudsman's recommendations carry a lot of weight and the CFPB respects the suggestions made in the report.

Data Point: Medical Debt and Credit Scores

Part of an occasional series of publications from the CFPB's Office of Research, this May 2014 report examines the impact on consumer credit scores of medical debt tradelines placed primarily by third party debt collection agencies.

Action Letters for Consumers Facing Debt Collection Action

On July 10, 2013, the CFPB published five action letters that consumers can consider using when corresponding with debt collectors.

  • Needs more information on the debt: This letter may be useful for a consumer who may not immediately recognize the debt as their own or for those who want to find out more about the debt before they pay it. View "more information" letter.
  • Wants to dispute the debt and for the debt collector to prove responsibility: This letter tells the collector that the consumer is disputing the debt and instructs the debt collector to stop contacting the consumer until they provide evidence that the consumer is responsible for that debt. View "dispute and proof" letter.
  • Wants to restrict how and when a debt collector can contact them: The FDCPA prohibits debt collectors from contacting a consumer about a debt at a time or place they should know is inconvenient. With this letter, the consumer is able to tell the debt collector how they would like to be contacted. View the "contact restriction" letter.
  • Has hired a lawyer: This letter template provides a way for the consumer to give the debt collector the lawyer's information and instruct the collector to contact only the lawyer. View the "hired a lawyer" letter.
  • Wants the debt collector to stop any and all contact: Consumers have the right to tell a debt collector to stop all communication. It is important to note that stopping contact from a debt collector does not cancel the debt or prohibit the collector from potentially pursuing other remedies, such as filing a lawsuit. View the "stop contact" letter.

CFPB Bulletin on FCRA Requirements for Consumer Reporting Agencies

The Bulletin, issued on September 4, 2013, specifically addresses furnishers’ obligations to “review all relevant information” they receive in connection with disputes forwarded by CRAs. Collection agencies are considered to be furnishers.

CFPB Organization Chart

The chart names the heads of divisions within the CFPB and gives an idea of how the agency is structured (current as of May 26, 2016)

CFPB 5 year Strategic Plan 2013-2018

Articulates the mission, vision, goals, and strategies for the CFPB and the steps leaders plan to take to achieve them. The CFPB's current version of its strategic plan was written, endorsed, and published in April 2013.

CFPB's Advice to the Consumer

Database of Q&A provided by the CFPB to consumers on hundreds of consumer finance topics. Approximately 70 questions are related to Debt Collection. If you get tired of clicking through to each individual question, you can download a nicely compiled and organized PDF here (for a modest fee of $79)

CFPB Coverage on


CFPB Issues New Guidance on Supervision of Service Providers

27 October 2016


CFPB Touts Innovation, But Not in Debt Collection

25 October 2016


Will Hensarling Letter to Cordray Do More Than Prolong Rulemaking?

24 October 2016


The U.S. Chamber is Resetting the Consumer Finance Discussion (So Keep Talking!)

24 October 2016


Debt Collection Industry Experts Consider Ramifications of Court Decision That Declared CFPB Structure Unconstitutional

17 October 2016


CFPB Plans Public Meeting on Debt Collection

17 October 2016


How the PHH Decision Could Limit CFPB's Enforcement Powers in Two Critical Ways

12 October 2016


Navy Federal Credit Union Agrees to CFPB Order, $28.5M Fine for Improper Collection Actions

12 October 2016


In Long Awaited Decision, DC Court of Appeals Rules CFPB Structure is Unconstitutional

11 October 2016


Will Supreme Court Provide Definitive Answer on Whether Filing Proof of Claim on Out-of-Statute Debt is an FDCPA Violation?

3 October 2016


Law Firm FOIAs, Publishes CFPB Enforcement Policies and Procedures Manual

3 October 2016


LendUp Feels Growing Pains As CFPB Orders Payment for Misleading Practices

29 September 2016


Consumer Advocacy Coalition Expresses Concern over CFPB Proposed Rules

26 September 2016


Former CFPB Attorney Pahl Joins D.C. Office of Arnall Golden Gregory

26 September 2016


LocateSmarter to Speak at Midwest Compliance Symposium about Using Call Disposition Data to Mitigate Risk and Improve Performance

23 September 2016