ROCKVILLE, Md. -- On September 18, 2019, the Consumer Relations Consortium (CRC) filed its comment on the Consumer Financial Protection Bureau’s (CFPB or Bureau) Notice of Proposed Rulemaking (NPRM) for debt collection. The NPRM set out to provide clarity to the outdated Fair Debt Collection Practices Act (FDCPA) and bring debt collection from the era of fax machines and telegrams to the modern era of electronic communications. CRC’s comment provides a comprehensive analysis of the Bureau’s proposal, covering what it got right, issues overlooked, and proposed amendments to make the final rule a workable solution.

“CRC members strive to collect the right debt, from the right person, in the right way and our comment reflects this common principle,” said Stephanie Eidelman, CRC Executive Director. 

CRC’s comment contains a detailed analysis—and proposed amendments where applicable—on specific issues in a section-by-section overview (e.g., email and text messaging procedures, call frequency limits, validation requirements, and the model validation notice). The analysis ties into a common set of themes:

  • Establishing clear expectations and guardrails for the host of activities associated with debt collection benefits consumers and the collection industry alike.
  • Safe harbors foster consistency and predictability, reducing consumer uncertainty about the debt collection process.
  • Certain parts of the debt collection process should produce a consistent consumer experience regardless of the type of debt. 
  • Consumers should have the ability to control how they communicate with debt collectors.
  • Rules should protect the least sophisticated and most vulnerable consumers without limiting those in the mainstream.
  • Technology has evolved—and continues to evolve—in ways that are out of the debt collector’s control.
  • Information overload is not unique to a consumer’s experience in debt collection, and the overarching goal of any processes and disclosures should be to “be clear and brief.”
  • Debt collectors and creditors are partners in the recovery process, and any regulatory rules should reflect this.

Some of the proposals offered by CRC include establishing safe harbor reasonable processing times for consumer requests similar to those outlined in the CAN-SPAM Act, a “right to cure” similar to that of California’s Rosenthal Fair Debt Collection Practices Act, and an alternate model validation notice structure that includes safe harbor text blocks that can be moved around the form as necessary for the debt collector to comply with the requirements of its creditors and vendors. 

Led by an editorial review committee, CRC members and their partners in the iA Innovation Council collaborated in the preparation of this comment. The editorial committee included the following: Leslie Bender (BCA Financial Services, Inc.), Andrew Blady (NCB Management Services, Inc.) Michael Kraft (The CCS Companies), Katie Grzechnik Neill (the iA Institute), and John Rossman (Moss & Barnett). 

You can download the final CRC comment letter here.

About the Consumer Relations Consortium

The Consumer Relations Consortium (CRC) is an organization comprised of more than 60 national companies representing the diverse ecosystem of debt collection including creditors, data/technology providers and compliance-oriented debt collectors that are larger market participants. Established in 2013, CRC is evolving the debt collection paradigm by engaging stakeholders—including consumer advocates, Federal and State regulators, academic and industry thought leaders, creditors and debt collectors—and challenging them to move beyond talking points and focus on fashioning real-world solutions that actually improve the consumer experience. CRC’s collaborative and candid approach is unique in the market.  CRC is managed by The iA Institute.

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About the iA institute

The iA institute (iA) is a media company that produces handcrafted news, events, and education for the consumer and commercial debt industry. The iA team believes that the value of your investment in our content should be undeniable, so we thoughtfully design everything we do with a focus on the details that make a difference. iA initiatives bring a range of stakeholders to the table in candid and intimate environments to inform, to collaborate, to innovate, and to make profitable connections. The iA institute, under the name insideARM LLC, is a certified woman-owned and woman-controlled business (WBE).

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