insideARM Weekly Recap – Week of December 2nd, 2024

Even at otherwise slow times of year it can seem like the news affecting the collections space moves at a mile a minute. Our weekly recap of top stories will give you the news we found most interesting last week and more importantly- why it’s relevant to the industry. Last week we covered 3rd quarter charge-offs and delinquency rates, whether the new DOGE should look at the CFPB, a recent litigation win regarding emails, and details on the CFPB’s new proposed FCRA Rule. 

On Monday, we highlighted an analysis of Q3 data from the Federal Reserve on credit card charge-offs and delinquencies. The numbers indicate an increase marking a 13-year high. This is the kind of information that can allow you and your business to plan for what is coming. With an estimated 9-12 months between charge-off and litigation, this data can help collectors know when to expect an increase in volume. 

On Tuesday, we published an opinion article from industry expert and a founding member of the CFPB, Jim McCarthy, that responded to a previous opinion piece and examined whether the upcoming Department of Government Efficiency (DOGE) should dig into the CFPB. Though opinions are not always news, we thought bringing you these opposing viewpoint articles would help shape the conversation around what a change in administration will look like for the CFPB and what that might look like for the industry and consumers. 

On Wednesday, we brought you details about a recent win in a case regarding email communications in which a court ruled that email, by its silent nature, is not the same as noisy calls. As the ARM industry relies more and more on electronic communications, cases like this will shape the path forward. Anyone sending electronic communications, or thinking about it, should take note of this decision.  

On Thursday, we reported that the CFPB proposed a new FCRA rule to expand its scope (though finalization is unlikely). This Troutman Pepper article broke down the details, but the highlight is that the proposed rule seeks to redefine terms and conditions in the FCRA, particularly as it relates to data brokers. The imminent change in administration does not mean we can tune out the CFPB’s proposals. As Troutman Pepper indicated, though this rule might not survive, it might serve as a blueprint for the states.  

As always, we thank you for reading the weekly recap to stay on top of this ever-changing industry! For a breakdown of the week of November 18th, click here.   

Have a question about how your company should react to the news above? We have a group for that! The weekly peer call hosted by insideARM’s Research Assistant is the perfect place to ask a question and get advice from industry colleagues who are facing the same challenges you are. Not sure if it is for you? Try it on for size with our 1-month free trial. Click here to learn more!