As I write this, it has been three weeks to the day since the CFPB released its proposed new rules for debt collection. After the initial frenzy of conversation, consumer groups and the debt collection industry have quietly retreated to their respective corners. As a watchdog over legislation, regulation and case law impacting the industry, I find their silence deafening. Both camps are assessing precisely how their world will change if the new rules, as proposed, become final without any significant change.
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