On April 7, 2021, the CFPB issued a Notice of Proposed Rule Making (NPRM) wherein it proposed delaying the effective date of the Debt Collection Rules (Regulation F) for 60 days. Reg F is scheduled to go into effect on November 30, 2021, and the proposed delay would push the effective date back to January 29, 2022.

According to the CFPB, extending the effective date would allow stakeholders affected by the pandemic additional time to review and implement the rules.  In the NPRM, the CFPB has asked stakeholders to comment on the following topics:

  • Should the Bureau extend the effective date of the Final Rule?
  • Is 60 days an appropriate length of time for such an extension?
  • Should safe harbors go into effect on November 30, 2021, even if Reg F does not otherwise take effect on that date?
  • Will there be any costs or other impacts caused by delay?
  • Is there an impact on small entities?

Stakeholders must submit comments to the CFPB 30 days from the date the NPRM is published in the Federal Register. The full NPRM, including instructions for submitting comments, can be found here.  

insideARM Perspective

It is important for accounts receivable entities to note that this is only a proposal to extend the effective date of Reg F; nothing has actually been decided yet.  Unless and until the CFPB actually delays the effective date, stakeholders should continue with their current plans to implement the requirements of Reg F by November 30, 2021.

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