CFPB vs. PRA-Top 3 Takeaways and PRA’s Response

Last week, the CFPB created a stir when it announced a Consent Order (Order) with Portfolio Recovery Associates (PRA), one of the nation's largest debt collectors and debt buyers. The 39-page Order is comprehensive. It imposes collection activity requirements not found in the Fair Debt Collection Practices Act (FDCPA) and litigation requirements typically left up to state law. It also provides insight into the CFPB’s mindset regarding collection activity, credit reporting, and what we might see proposed as rulemaking.

Here are the top 3 things ARM industry participants should know:

1. The Consent Order stems from the 2015 Consent Order between the CFPB and PRA.