Earlier today we reported that the CFPB has taken the long-awaited next step in debt collection rulemaking activity by releasing an Outline of Proposed Rules in advance of the required Small Business Regulatory Enforcement Fairness Act (SBREFA) consultation process. The formal SBREFA hearing is scheduled for the week of August 22.
The Outline of the CFPB’s Proposed Debt Collection Rules is a 117-page document. However, the guts of the proposals are covered in the first 71 pages. The remainder includes the appendices. There is a lot to digest. The ARM industry will like some elements of the proposal; there are other elements that are likely to cause some heartburn. There is too much to fully address in any one post; therefore we will address the various proposals in a series of analysis articles. This first article addresses the proposals related to voice messages and contact frequency.
Voice Messages
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