The Consumer Financial Protection Bureau (CFPB) recently finalized its rule and examination procedures for supervising larger market participants in the accounts receivables management industry. Beginning in January 2013, collection agencies, debt buyers and attorneys with more than $10 million in annual receipts from consumer debt collection-related activities will be subject to an examination of business practices.

The effects of CFPB supervision will resonate industry-wide. Service providers and smaller agencies, in particular those working with banks or other regulated entities, could find themselves impacted and also under the CFPB’s purview. Additionally, early next year the bureau will add consumer debt collection to its complaint resolution program.

ACA International is committed to being your primary resource on the CFPB and has announced that a comprehensive CFPB Compliance Program to help members is coming soon. Based on an analysis of information regarding the CFPB’s examinations, ACA is finalizing a suite of compliance, training and examination resources to help navigate the practical application of this supervision. Among the resources to be available to your business:

  • Advocacy: Since the CFPB’s inception, ACA has been your voice to help the bureau better understand the complexities of the ARM industry and advocate for industry priorities. Through personal meetings with Director Richard Cordray and others within the CFPB, ACA has established an excellent working relationship with the CFPB and has reiterated our willingness to be a resource. We’ll keep you up-to-date on critical information that may affect your business.

  • Information: ACA members now have easy access to the most recent CFPB news and information, videos and links to invaluable resources, links to webcasts of congressional and CFPB field hearings, written testimony from congressional hearings, and ACA comments and other submissions.

  • Training: Since the CFPB’s announcement in late October, ACA has already hosted three timely and information-packed teleseminars for members and is planning future programs for you and your employees. Educational and training programs will also be available at future ACA meetings, including Spring Forum, Annual Convention and Fall Forum.

  • Learning: ACA is convening a CFPB Examination Workgroup, comprised of the larger market participants, to share their experiences and foster discussion to help the industry as a whole better understand the examination process.

  • Preparation: ACA has quality assurance resources to help members get ready for CFPB examinations. Our Professional Practices Management System is an effective management system for collection agencies based upon developing, implementing and adhering to a set of industry-specific professional practices and policies.

  • Compliance: ACA will continue to provide members with the best compliance materials available. Additionally, the Credit and Collection Compliance Officer designation is designed specifically for credit and collection professionals in compliance-related positions.

The recently issued CFPB Examination Procedures notes that examiners will be looking at audit and compliance reports. ACA’s certified instructors and time-tested programs, both PPMS and CCCO, are available to you and your company to help you prepare for the new environment of CFPB supervision.


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