2013 was the year the federal government resolved to take serious action against bad actors in the debt collection industry. 2014 should be the year that everyone in ARM makes some New Year’s resolutions of their own to avoid pricey compliance headaches.
5. Don’t start slacking on your resolutions by February 1 like everyone else does. In fact, there’s a built-in deadline to keep the industry motivated. The CFPB’s comment period on its Advance Notice of Proposed Rulemaking ends February 16. At that point, the Bureau will sort through comments from collectors and consumers to decide next steps in how to regulate the industry. Right now, the most active discussions surrounding the ANPR deal with debt collection litigation and questions about the appropriate use of mobile technologies in debt collection. These are topics that debt collectors, buyers and lawyers have a wealth of knowledge on; they should be encouraged to speak up.
4. Watch your vendors like a hawk. The CFPB made it clear in 2013 that if a collection agency’s third-party vendor is out of line, then the agency itself may be held accountable for that vendor’s violation. No example of this was more clear than the consent order between JP Morgan Chase and the Office of the Comptroller of the Currency. The language of the consent order stands to have a massive ripple effect throughout the debt collection industry because it essentially creates a blueprint for dramatic oversight by banks over their collection agencies, lawyers and debt buyers. Learn more with our report, To the Point: The Chase Consent Order.
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