When the Bureau of Consumer Financial Protection (Bureau of BCFP) announced it would be accepting applications for new members to its Consumer Advisory Board (CAB or Board), insideARM published an article asking whether the Bureau would choose more than one ARM industry representative for the Board. On Friday, the industry finally got its answer, and that answer is no.
In June Acting Director Mick Mulvaney disbanded all advisory boards, including CAB, saying the boards were too big and that they cost too much to operate. He said at the time that boards would be selected (and none of the just released members would be eligible to participate). Last Friday afternoon the Bureau announced its appointments. While the new CAB contains a member in the loan servicing space, noticeably absent from the list, in a year when rulemaking is expected, is representation from the debt collection industry.
The new CAB members include:
- Liz Coyle, Executive Director, Georgia Watch, a consumer advocacy group in Georgia.
- Sameh Elamawy, Chief Executive Officer, Scratch Services, Inc., a technology-based loan servicing company. Prior to joining Scratch, Mr. Elamawy was a product manager at both DropBox and Pinterest.
- Manning Field, Chief Operating Officer, Acorns, a mobile investing app that rounds up purchases made to the nearest dollar and invests the difference in the market. Prior to joining Acorns, Mr. Field spent many years at Chase in multiple roles, including those related to marketing and innovation.
- Jason B. Gross, Chief Executive Officer, Petal, a credit card provider. Mr. Gross worked as an attorney prior to his current role.
- Clinton B. Gwin, President and CEO, Pathway Lending, a loan provider.
- Ronald A. Johnson, President, Clark Atlanta University. In addition to his many roles in higher education, Dr. Johnson is also an investment management consultant.
- Brent Neiser, Senior Director of Strategic Programs and Alliances, National Endowment for Financial Education. Mr. Neiser is the only member of the dismantled CAB that was appointed to the new CAB.
- Sophie Raseman, Director of Product, Brightside, a service created to benefit employees by optimizing their net income. Ms. Raseman previously served as the Director of Smart Disclosures for the U.S. Treasury Department and was the co-chair of the Task Force for Smart Disclosures for the National Science and Technology Council.
- Luz Urrutia, Chief Executive Officer, Opportunity Fund, a non-profit micro-lender.
As mentioned above, noticeably missing from this list is representation of the debt collection industry, which the BCFP oversees. The previously-dismantled CAB contained a single ARM industry member, the CEO of True Accord, Ohad Samet. Samet was a new-comer to the industry, and the leader of what is essentially a technology firm with a business model quite different from traditional collection agencies. He was viewed by many as an interesting choice, as he had limited background in debt collection. Nonetheless, he has been effective in leading many to accept the new idea that there may be a path to primarily email-based collections.
Prior to that, Joann Needleman, member at Clark Hill and leader of the firm's Consumer Financial Services Regulatory & Compliance Practice Group, served as the sole industry member on the CAB until her 3-year term expired. Needleman was previously president of the National Creditors' Bar Association, and was widely viewed as a solid choice to represent the industry.
The choice to not include debt collection representatives on the CAB -- and the extremely brief section devoted to debt collection in the Bureau’s Supervisory Highlights released last week -- leave some wondering what the future focus on the debt collection market will look like. The industry has been fiercely advocating for rules that specifically accommodate modern technology for use in communicating with consumers. Given the multiple technology-based companies on the CAB, and the Bureau's newly formed Office of Innovation, perhaps the door has opened.