Six months after it first announced its pilot program, the Consumer Financial Protection Bureau (CFPB or Bureau) officially launched its Advisory Opinion Program by finalizing its advisory opinion policy yesterday. The policy is designed to provide clarity in areas where there might be regulatory uncertainty.
The advisory opinion program is of special interest to the debt collection agency. With the recent release of its final debt collection rule—Regulation F—the CFPB specifically cited the advisory opinion program as a place for debt collectors to seek clarification of the new requirements and safe harbors. The final rule is a tremendous document that took roughly seven years to finalize, but it is also complex as it seeks to bring current an outdated statute, the Fair Debt Collection Practices Act. With such an overhaul, questions are bound to present themselves as debt collectors begin the process of implementing the rule's requirements.
According to the CFPB's final advisory opinion policy, "any person or entity" can submit a request for an advisory opinion by email to advisoryopinion@cfpb.gov. The policy adds:
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