What is ACA working on right now? Here’s a recap of our recent projects and news coverage, focused on leadership goals, ongoing advocacy on the CFPB’s regulatory approach and updates on medical debt credit reporting and text messaging.
08/31/2022 2:15 P.M.
5 minute read
ACA International’s team is dedicated to being an ally for members through advocacy, education, compliance resources, communications strategies and much more.
In July, we released our 2022 Midyear Accomplishments report, which details our advocacy leadership at the state and federal level, compliance resource improvements, member services updates and unmatched access to industry education.
But we’re always working on something. Check out these highlights from August that build on the accomplishments in our most recent report—all to help members succeed.
ACA President Courtney Reynaud Shares Leadership Vision
At ACA’s Convention & Expo in July, Reynaud took the stage at the president’s closing celebration to begin her term as president, bolstered by years of experience in leadership and advocacy. Read about her vision for the year ahead here.
Making Connections with Lawmakers at ACA Events
In the last year, ACA’s Board of Directors, under the leadership of 2021/22 President Kevin Baich, has prioritized meeting with members of Congress during our annual events, including Fall Forum, IGNITE, the Convention & Expo and Washington Insights Fly-In. That continued during the 2022 Convention & Expo in Orlando last month when U.S. Rep. Josh Gottheimer, D-N.J., a member of the House Financial Services Committee, met with ACA members and staff, which you can read about here.
Summarizing New Cybersecurity Exam Procedures
The Conference of State Bank Supervisors (CSBS) has released two new tools for nonbank financial services companies to improve their cybersecurity exam procedures and practices. The Baseline Nonbank Cybersecurity Exam Program and the Enhanced Nonbank Cybersecurity Exam Program are tools used by state examiners nationwide to assess the cyber preparedness of nonbank entities.
Reviewing these exam procedures and resources on cybersecurity will help ensure compliance in protecting consumer data and prepare for review by state regulators.
It’s also critical to make sure your cyber liability insurance is current. A cyber liability insurance policy is designed to protect you from lost income and cover defense fees your business may be required to pay as a result of a data breach.
Read more on these resources here.
What Does it Mean? VantageScore’s Medical Debt Collection Record Change
VantageScore recently announced that neither of its most recently introduced scoring models will continue to use medical debt collection data in the calculation of consumers’ credit scores, regardless of the amount owed or the age of the collection effective in mid-October. ACA broke the news and shared insights on its impact for consumers, much like other medical debt credit reporting changes this year.
ACA CEO Scott Purcell said that ACA can appreciate the work done by VantageScore, concluding that medical debt, unpaid or paid, may not be as strongly a correlated predictor of debt repayment for consumers as other indicators.
“However, we believe medical debt in collections should very much still show as tradelines on a credit report so that future credit grantors truly know the overall financial picture of that borrower in terms of repayment ability, and so the consumer knows about the debt,” Purcell said.
Read the latest on the Vantage Score changes here.
ACA, Industry Trade Groups and Small Business Administration Request Extension of FTC Safeguards Rule Deadline
Advocacy efforts are increasing for the Federal Trade Commission to extend its effective date for the Standards for Safeguarding Customer Information rule from Dec. 9 this year to Dec. 9, 2023. The rule requires financial institutions to develop, implement, and maintain a comprehensive information security program.
In July, on behalf of their members, ACA, the American Financial Services Association, the Consumer Data Industry Association and the National Automobile Dealers Association submitted a letter to the FTC requesting the deadline extension.
Read more on the extension request here.
ACA Advocacy: CFPB Director Rohit Chopra’s Approach to Regulations is Taking Away Consumer Choice
ACA’s advocacy team continues to engage with regulators and lawmakers on the impact their decisions have on the accounts receivable management (ARM) industry and consumers.
As part of that engagement, ACA also shares its advocacy with the public and media—for example, in a recent article by CEO Scott Purcell published in American Banker, “CFPB Director Rohit Chopra’s Approach to Regulations is Taking Away Consumer Choice.”
Read an excerpt from the article here.
Text Message Solutions
On a recent ACA Huddle for members, Michael H. Pryor, shareholder at Brownstein Hyatt Farber Schreck, and Amanda Payton, general counsel with Solutions by Text, provided an update on the text messaging regulatory framework for the ARM industry and reminders on how to work with carriers to ensure compliant text messaging procedures are in place.
ACA supports laws and regulations to limit illegal robocalls and unwanted text messaging communications, while also continuing to advocate that legitimate businesses need these communications methods based on consumer preferences.
Read more on what we know about text messaging carriers’ debt collection restrictions here.
Advocating for Balanced Approach in Robocall Mitigation Efforts
A recent proposed rulemaking from the Federal Communications Commission on foreign-originated illegal robocalls and call authentication is drawing concerns from joint industry trade groups that it will result in legitimate, lawful calls being blocked.
To present those concerns and possible solutions, ACA, the Credit Union National Association, American Financial Services Association, National Council of Higher Education Resources, National Association of Federally-Insured Credit Unions and the Student Loan Servicing Alliance filed comments with the FCC on the proposal under Advanced Methods to Target and Eliminate Unlawful Robocalls and Call Authentication Trust Anchor Docket No. 17-59.
As a proposed solution, the groups respectfully urge the FCC to avoid imposing excessive restrictions on providers that originate and transmit “non-conversational traffic, which also appears to include communications such as fraud alerts, school closings, payment reminders and many other types of legitimate calls that members routinely make to their customers.”
Read the latest on advocacy with the FCC on this issue here.
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