On December 8, 2020, the Consumer Financial Protection Bureau (CFPB) entered into a Consent Order with RAB Performance Recoveries, LLC (RAB) for engaging in debt collection activity without a license in the states of Rhode Island, Connecticut and New Jersey. RAB’s failure to obtain any proper state licensing in those specific states led the CFPB to issue a fine of over $200,000 as well as a permanent order restraining RAB and its principals from ever engaging in a very broad description of debt collection activities. Both state regulators and the CFPB are responsible for regulating debt collection activities and both have a vital interest in the work of the other. However, in this instance, the CPFB acted alone and found that RAB’s conducted not only violated the Fair Debt Collection Practices Act (FDCPA), but their conduct amounted to a UDAAP violation under the Consumer Financial Protection Act of 2010 (CFPA).
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