Although California’s licensing application is due by December 31, 2021, California’s Department of Financial Protection and Innovation (DFPI) continues to propose modifications to its debt collection licensing requirements.
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On October 29, the New York Department of
Financial Services issued proposed amendments to 23 NYCRR 1, its regulation
titled “Debt Collection by Third-Party Debt Collectors and Debt
Buyers.” The proposed amendments would make significant
changes to the sections of the current regulation dealing with initial
disclosure requirements, statute of limitations disclosures, substantiation
requirements, and telephone and electronic communications. They would also align the DFS regulation with several of the CFPB’s requirements in Regulation F. Regulation F is set to become effective on November 30, 2021.
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Just before noon today, the Eleventh Circuit Court of appeals issued an order (Order) vacating its opinion in Hunstein vs. Preferred Collection & Management Services, Inc, 994 F.3d 1341 (11th Cir. 2021), which means Hunstein is no longer good law.
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