The Consumer Financial Protection Bureau (CFPB or Bureau) filed its semiannual regulatory agenda on June 21, 2019. The agenda discusses the many rulemaking initiatives undergone by the Bureau recently, including the Notice of Proposed Rulemaking on debt collection (NPRM). The agenda states that the NPRM “address[es] such issues as communication practices and consumer disclosures in the debt collection market.”

The agenda continues:

This proposal builds on research and pre-rulemaking activities regarding the debt collection market, which remains a top source of complaints to the Bureau. The Bureau has also received encouragement from industry and consumer groups to engage in rulemaking to address how to apply the 40-year old Fair Debt Collection Practices Act (FDCPA) to modern collection practices.

Other rulemaking activities outlined by the Bureau in the agenda include clarification regarding amendments to the Home Mortgage Disclosure Act (HDMA), reconsideration of the Payday Rules, and forthcoming continuation on rules to implement section 1071 of the Dodd-Frank Act, which amended the Equal Credit Opportunity Act.


insideARM Perspective

The CPFB has certainly had a busy year all-around, and the proposed debt collection rules seem to make up a good portion of it. After many years of research and preparation, the NPRM was released on May 7. The following day, Director Kathleen Kraninger hosted a debt collection Town Hall in Philadelphia, where Stephanie Eidelman, the Executive Director of the Consumer Relations Consortium and CEO of The iA Institute, spoke as a panelist.

The NPRM was officially published in the Federal Register on May 21, triggering the clock to submit comments (which are due by August 19, 2019). Consumers, consumer advocates, senators, and industry members have already begun submitting comments; fifty-seven have been submitted thus far. Many more are likely to come in the next few months as everyone digests and thoughtfully prepares their response to the 500+ page NPRM.

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