BCFP’s Tom Pahl Provides Candid Update on Debt Collection Rulemaking


Pahl spoke with ACA CEO Mark Neeb and members in attendance at the 2018 Fall Forum & Expo about the upcoming industry rulemaking and the potential impact of the midterm election results on the bureau.

11/8/2018 9:00

If there is one message that Tom Pahl, the Bureau of Consumer Financial Protection’s policy director for research, markets and regulation, and keynote speaker at ACA International’s 2018 Fall Forum & Expo, made clear during his presentation Thursday, it’s that the bureau wants to hear from ACA members and accounts receivable management industry professionals as it moves forward with the debt collection notice of proposed rulemaking expected in March 2019.

“I want to encourage ACA to comment on every issue on which you have interest, concerns [and] things you wish to support,” Pahl said in a question-and-answer discussion with ACA CEO Mark Neeb.

Pahl said the bureau is proceeding with the March 2019 timeline for the Notice of Proposed Rulemaking and that at this time he does not anticipate the confirmation of a permanent director to replace Acting Director Mick Mulvaney to impact that timing.

President Donald Trump’s nominee for the bureau director post, Kathy Kraninger, is awaiting confirmation by the U.S. Senate.

“We are not anticipating right now that having someone new come in will affect the timeframe. At this point we don’t know when Kathy Kraninger is likely to be confirmed by the Senate,” Pahl said. “I think the conventional wisdom is she will be confirmed, we just don’t know when.”

Meanwhile, the bureau will also proceed with seeking public and industry comment on the rulemaking, said Pahl, noting that the goal is to allow more time for comments and to encourage small businesses to make their voice heard.

“It’s extremely valuable [for] us to hear from small firms,” Pahl said, adding that is why it is valuable to hear from ACA members.

Neeb and Pahl stressed the rulemaking and comment process will also be a time to address industry concerns about the bureau’s complaint database and methods to communicate with consumers.  The bureau also continues to review comments in response to the series of requests for information on bureau functions completed earlier this year, Pahl said, noting the bureau received the most comments about consumer complaints.

“I really truly believe that ACA members want a robust complaint database, so what’s important to members is having that database as accurate and succinct as possible,” Neeb said. “However, ACA continues to advocate that the bureau should improve its approach to the complaint database by including more accurate cataloguing and reporting of complaints.”

In discussions with Neeb, Pahl also provided an update on how Tuesday’s midterm election results and new Democratic majority in the U.S. House of Representatives may impact oversight of the bureau.

At press time, the split in the House was 222 seats for the Democrats and 197 seats for the Republicans. In the Senate, the Democrats hold 46 seats compared to the 52 seats for the Republicans as two races (Arizona and Mississippi) remain undecided.

According to Pahl, the new majority leadership in the House could present more hearings calling for testimony from the bureau.

Pahl also addressed the BCFP’s top priorities for the coming months and details about the bureau’s approach to developing rules to regulate the industry as well as his insights related to debt collection research conducted by the BCFP to inform its decision making.

Concluding Thursday’s opening general session, Vice President of Congressional and Political Affairs Rae Ann Bevington provided an important update on the elections.

“The political landscape continued to evolve up until election day,” Bevington said. “We really all need to build relationships with our members of Congress.”

For more information, read ACA’s coverage: Midterms 2018: Impact on the ARM Industry and listen to the latest ACA Cast episodes available online. Bevington will be providing additional updates on the federal actions in an additional episode of ACA Cast following the Fall Forum & Expo.

ACA’s 2018 Fall Forum & Expo continues through Friday, Nov. 9 at noon central with additional health care, legal and business intelligence sessions.

To view the full event agenda or to download the interactive guide, visit the ACA International 2018 Fall Forum & Expo website. This feature also enables attendees to plan their program, connect with other attendees, browse sponsor and exhibitor profiles, access session materials and more.

An interactive guide for the Fall Forum & Expo is available by downloading Guidebook from the app store on your mobile device. Once installed, tap “Find Guides” then tap “Enter a Passphrase.” Enter the passphrase 2018acaff to download the app to your device. Guidebook is also available online at

ACA International also encourages attendees to share their Fall Forum & Expo experiences on social media using #ACAFallForum18.

Thank you to our Fall Forum sponsors! ACA International would like to acknowledge and thank the event sponsors Solutions by Text, Venable LLP, VoApps, Quantrax Corporation, Telrock and Tracers for their support of this important industry event.  

Interested in becoming a sponsor at future ACA events? For more information, please contact Member Services at [email protected] or 800-269-1607.

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