How Engaged is the CFPB with the ARM Industry?

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Gina McNaughton

October 10, 2012 started out like most mornings for me; however, this day was different. While reading Twitter, part of my daily routine, I read a new tweet from the Consumer Financial Protection Bureau (CFPB). It was a “Save the Date” request for a field hearing in Seattle on October 24, 2012, on debt collection. Now my interest was piqued.

Attached to the tweet was a link to the announcement on the CFPB’s blog. The only additional information was that CPFB Director Richard Cordray would be providing remarks and they even would feature testimony from consumer groups, industry representatives, and members of the public, and that it started at 10AM (I have to assume local time, but even that detail was not included). There was an open invitation for attendees, along with a CFPB dedicated e-mail address for RSVP.

Yes, that was it.

I read it again several times hoping I may have missed something. I didn’t. I searched for a Press Release and found nothing. Wait a minute; this is the CFPB’s first field hearing regarding debt collection and there’s no Press Release, no location information, no contact name, or phone number? Questions, questions, questions.

The first thought I had was that the CFPB would use this field hearing to issue its final rule on “larger participant” supervision, specifically the size requirements for collection agencies that will be actively supervised. This final rule announcement was pushed back earlier in the year.

I posted the field hearing announcement in a few debt collection LinkedIn Groups, including my own, and I received the same feedback. Why all the missing pieces to this important announcement? One post remarked that even the debt collection associations — ACA, DBA and NARCA — had not been notified of this debt collection field hearing. So, who are the “industry representatives” providing “testimony” at this field hearing? Well, it’s still a mystery.

So, with little hesitation, I e-mailed my RSVP to the CFPB on 10/10/2012. I noted my qualifications as a debt collection subject matter expert. I did not receive the standard “we received your request” reply e-mail, so I verified the e-mail address again. The next day, I followed up with a phone call. The original CFPB number was now not in service, so I called the Inquires line (not the complaint line), hoping to speak to someone that could provide more details. The phone call lasted four minutes.

These are the CFPB’s Representative’s responses: “What was the field hearing called?” “Hold on a minute”  “Which field hearing again?” After a 3 ½ minute hold, “Let me take your name, and number, and someone will get back to you.” As of today, 10/17/2012, I still have not received a response to my RSVP (sent 10/10), or a response to my message left with the Representative from the CFPB Inquires Department. As a reminder, this event is taking place exactly one week from today.

In my opinion, the mainstream perception of the CFPB is that they are partnering with the financial services industry to better serve and protect consumers. The reality is that while they may, or may not, be working with banks, lenders, and other financial services providers, their partnership with the debt collection industry appears almost non-existent. As you may be aware, the CFPB recently appointed the Consumer Advisory Board (CAB) which was a part of the Dodd-Frank legislation. A review of the Board Members selected shows most of the financial sectors are represented, except for the ARM industry. Why?

I wish I could tell you that I will be attending the first ever CFPB field hearing on debt collection; however, with no location information, lack of response from the CFPB to my RSVP e-mail, coupled with the date nearing next week, it is not certain that I will be attending. I guess we’ll have to wait and see.

Gina McNaughton is a recognized Debt Collection Subject Matter Expert (SME) with over 20 years leadership experience in the accounts receivable management (ARM) industry. She leads The McNaughton Group, a boutique consulting firm, which audits 3rd party debt collection agencies on behalf of Clients, provides internal operational audits/training directly to 3rd party debt collection agencies, and provides legislative support on credit and collection related matters.  In addition, she is also a frequent speaker on Financial Literacy, and the owner of the Debt Collection LinkedIn Group, Debt Collection FDCPA—FCRA—FACTA—GLBA—TCPA—FTC & CFPB Regulations Forum, the place to discuss best practices & share information about important regulations affecting the Debt Collection Industry.

Continuing the Discussion

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  • avatar Gizboo says:

    I received a response yesterday, unsigned, from the same email address posted for the RSVP.

    Thank you for your RSVP for the CFPB field hearing on debt collection on Wednesday, October 24 at 10:00am PST in Seattle, Washington.

    You are confirmed to attend.

    The venue will be confirmed soon and you will receive another notification with the exact address.

    Feel free to forward the invitation, and we look forward to seeing you on October 24.


    The Consumer Financial Protection Bureau

  • avatar SterlingBP says:

    I actually felt it was a setup, with a pre-picked group of consumer groups ready to attack any representatives from ARM industry that showed up.

  • avatar Gina McNaughton says:

    I just received the same response as Gizboo above. Confirmed to attend, but the venue still unconfirmed. Very short notice for booking travel, < 1 week.

  • avatar paybill says:

    Your government in action! Do you really expect anything different? Remember this come election day.

  • avatar Mavis Pye says:

    Someone from the CFPB posted the following when people began asking for details on location of this event:

    CFPB Web TeamMOD•a day ago•parent−

    The meeting has ended, but you can see the meeting here:


    Share ›

  • avatar Gina McNaughton says:

    Looks like the CFPB Web Team Member was confused on the field hearing. The video they posted was for the CAB 1st meeting in St Louis, held last month.
    Let’s hope the CFPB’s Debt Collection field hearing next week is also available via webcast. As of this post, still waiting for a confirmed location.

  • avatar chuck-decresie says:

    It never amazes me how disorganized many of our “governing bodies” can appear. Of course, if you want to rule out all those opposing views to proposed change, the easiest way is simply not to allow them access to the “scheduled venue”. I don’t believe I’d call that “partnering with the financial services industry”…I’d be more apt to call it muzzling or crippling the industry.

  • avatar RGS Financial Inc says:

    Unfortunately, I’m afraid the ARM industry will be considered by the CFPB to be guilty until proven innocent. It will be interesting to see how many of the “industry representatives” attending the hearing are from consumer advocate groups and debtor attorneys out to paint bleak picture of our industry in order to make a quick dollar.

    - Paul Gauerke, Owner/CMO RGS Financial

  • avatar Gina McNaughton says:

    Just received this:

    Thank you for your RSVP for the CFPB field hearing on debt collection on Wednesday, October 24 at 10:00am PST in Seattle, Washington.

    You are confirmed to attend.

    UPDATE: The venue has been confirmed. The field hearing will be held at the Seattle Public Library (Auditorium), 1000 4th Avenue, Seattle, WA 98104.

    Feel free to forward the invitation, and we look forward to seeing you on October 24 at the Seattle Public Library.


    The Consumer Financial Protection Bureau

  • avatar Wendy Badger says:

    ACA International is reporting that Carrie Finney of the CMI Group, Chad Benson of CBE Group and Bill Allen of ALW Sourcing will be representing the collection industry as panelists at the CFPB field hearing on debt collection.

  • avatar Mavis Pye says:

    I hope they do a webcast, or at least put make it available afterwards like they did on this one.

  • avatar Gina McNaughton says:

    Anyone else attending the debt collection field hearing this week?

  • avatar JCT says:

    Webcast should be available at Look at the “blogs” section for link, I believe.

  • avatar Gina McNaughton says:

    Same info posted on the CFPB Blog

    Only update, is the location. In addition, the comments section was closed last week too. The length of the field hearing, still an unknown, as well as the Agenda.

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