CFPB Bites of the Month – 2023 Annual Review – Debt Collection

Editor's Note: This article, authored by Anastasia V. Caton, Charles F. Dodge, Jr., Eric L. Johnson, Justin B. Hosie, and Laura J. Bacon previously appeared in Hudson Cook’s Insights Blog and is re-published here with permission. This article is provided for informational purposes and is not intended nor should it be taken as legal advice. The views and opinions expressed in this article are those of the authors in their individual capacity and do not reflect the official policy or position of the partners of Hudson Cook, LLP or clients they represent.

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In this article, we share a timeline of our monthly "bites" for 2023 applicable to debt collection. If debt collection in 2023 had a theme it would be medical debt. Medical debt woes transcend political parties and affect nearly all demographic groups. As the CFPB has pointed out, and as almost every American knows, medical bills are confusing and insurance disputes are common. The CFPB took aggressive action in 2023 to curb medical debt collection practices and to ensure that medical debt collectors are collecting on accurate, undisputed amounts.

While it was active and aggressive, the Bureau clearly sensed an existential threat to its authority. The U.S. Supreme Court's decision about its funding structure loomed in the background for most of the year. And the Bureau's public statements throughout 2023 took pains to highlight the authority of states and the Federal Trade Commission to enforce the Fair Debt Collection Practices Act and the Consumer Financial Protection Act's prohibition on unfair, deceptive, and abusive acts and practices.

Bite 10: CFPB Finds 33% Decline in Collections Items on Consumer Credit Reports

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