ROCKVILLE, Md. -- On September 18, 2019, the Consumer Relations Consortium (CRC) filed its comment on the Consumer Financial Protection Bureau’s (CFPB or Bureau) Notice of Proposed Rulemaking (NPRM) for debt collection. The NPRM set out to provide clarity to the outdated Fair Debt Collection Practices Act (FDCPA) and bring debt collection from the era of fax machines and telegrams to the modern era of electronic communications. CRC’s comment provides a comprehensive analysis of the Bureau’s proposal, covering what it got right, issues overlooked, and proposed amendments to make the final rule a workable solution.
“CRC members strive to collect the right debt, from the right person, in the right way and our comment reflects this common principle,” said Stephanie Eidelman, CRC Executive Director.
CRC’s comment contains a detailed analysis—and proposed amendments where applicable—on specific issues in a section-by-section overview (e.g., email and text messaging procedures, call frequency limits, validation requirements, and the model validation notice). The analysis ties into a common set of themes:
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