On Friday afternoon, the Consumer Financial Protection Bureau (CFPB) released its long-awaited Supplemental Notice of Proposed Rulemaking (SNPRM) for time-barred debts. The CFPB first hinted that an SNPRM was coming last year when it included a placeholder for time-barred debts in its full NPRM for debt collection, as well as when it launched a consumer survey for time-barred debt disclosures. As recently as December, the CFPB noted that the SNPRM would be coming "very early in 2020"—and now it is here.
The Proposed Disclosures
Following the path of certain states that already require time-barred debt disclosures, the CFPB has created three separate proposed disclosures that would be applied to applicable situations. First is the general time-barred disclosure, to be used on all time-barred debs:
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