When the CFPB released their advisory opinion on “pay-to-pay fees” in debt collection, it caused confusion in the debt collection industry. The opinion emphasized the existing provision in the FDCPA that says debt collectors may not collect fees that are “incidental” to the principal amount of the debt unless expressly permitted by law or within the consumer’s agreement with the creditor.
But, that has been the governing law in debt collection since the FCPA was passed in 1977. So why even bother with publishing the advisory opinion? Digging deeper into the opinion, there are a few key points of clarification:
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