On March 8, 2021, the Consumer Relations Consortium (CRC) responded to the California Department of Financial Protection and Innovation’s (DFPI) request for comment regarding the implementation of the California Consumer Financial Protection Law (CCFPL). Consistent with what appears to be a trend by individual states to create mini versions of the CFPB, California has enacted the CCFPL, which may ultimately affect receivables management entities across the industry.
The DFPI asked stakeholders to comment on various topics to help identify issues and present potential solutions. Multiple industry groups submitted comments, including the Consumer Relations Consortium (CRC). Comprised of more than 60 national companies representing creditors, data/technology providers, and compliance-oriented debt collectors, the CRC leveraged its multifaceted expertise in the receivables management industry to prepare comments for the DFPI, including suggestions regarding:
- Establishing clear and concise definitions which are consistent with other laws.
- Outlining the exact parameters regarding the types of debt and specific industries which will be subject to the CCFPL.
- Ensuring complaint procedures require certain information from consumers and allow entities sufficient time to respond to complaints.
- Creating a clear, transparent, and easy-to-follow licensing process.
- Evaluating the efficacy of disclosures before enacting any disclosure requirements
- Reviewing disclosures for consistency with other applicable laws
You can download the final CRC comment letter here.
About the Consumer Relations Consortium
The Consumer Relations Consortium (CRC) is a membership group for forward-thinking organizations that wish to influence the direction of collections compliance, legal strategy, and regulatory policy. The CRC is 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 is managed by The iA Institute.
Learn more at www.crconsortium.org.
About the iA institute
The iA Institute is a media company that provides news, education, events and connection for professionals in consumer finance. The iA team believes the value of your time and investment in our content should be undeniable, so we thoughtfully design everything we do with a focus on the details that make a difference. Our initiatives include the flagship website and newsletter insideARM; the Consumer Relations Consortium (CRC) and iA Innovation Council membership groups; the iA Research Assistant and Case Law Tracker premium subscriptions; the iA Strategy & Tech digital conference; and the uniquely engaging annual Women in Consumer Finance event. iA is a certified Woman-Owned business.
Learn more at www.theiainstitute.com.