Regulatory Recap: Comment Requests on ‘Employer-Driven Debt’ and Call Authentication Ongoing; FTC Enforces Credit Karma’s Offers

regulatory recapRead our recap of regulators’ comment requests of note for the accounts receivable management industry and an update on the FTC’s enforcement activity.


4 minute read

The Consumer Financial Protection Bureau and Federal Communications Commission recently announced comment request updates on “employer-driven debt” and call authentication framework rules, respectively.

At the Federal Trade Commission, an enforcement action surfaced last week against credit services company Credit Karma for allegedly offering consumers pre-approved credit offers they ultimately did not qualify for.

Here is a rundown of these regulatory activities:

CFPB Comment Deadline on ‘Employer-Driven Debt’ Extended

The CFPB Request for Information (RFI) seeking data about, and worker experiences with, emerging practices and financial products referred to as “employer-driven debt,” is now open through Sept. 23, 2022. Comments were originally due on Sept. 7.

The CFPB is interested in knowing whether consumers have a meaningful choice in accepting employer-driven debt products. The CFPB also wants to understand the terms and conditions for these products, including whether they might impede someone from seeking a better-paying job, according to a news release from the bureau.

Employer-driven debt comprises an emerging set of products and services that the CFPB is studying to better understand the potential impact on individual borrowers, jobseekers, and the broader labor market, according to the bureau.

A report from the U.S. Chamber of Commerce shows the CFPB’s RFI is problematic for businesses, ACA International previously reported.

Bill Hulse, vice president for Capital Markets Competitiveness, and Glenn Spencer, senior vice president, employment policy division, for the U.S. Chamber of Commerce say this study and the RFI will create difficulties for businesses’ need to hire and train employees.

“While it sounds innocuous, the RFI is targeted at common business practices that expand hiring opportunities and provide employees with in-demand skills,” Hulse and Spencer wrote in the Chamber of Commerce report. “Frequently, when companies hire new employees, they provide them with the opportunity to undertake training or certification courses. In return, employees will often agree to stay with the company for a limited amount of time or otherwise assume the burden for their repayment.”

Read the complete article here. The bureau’s RFI is available on the Federal Register.

FTC Issues Enforcement Action Against Credit Karma

The Federal Trade Commission has taken action against credit services company Credit Karma, alleging that the company used claims that consumers were “pre-approved” for credit cards and had “90% odds” to entice them to apply for offers that, in many instances, they ultimately did not qualify for, according to a news release.

The agency’s order requires the company to pay $3 million that will be sent to consumers who applied for these credit cards and to stop making these types of deceptive claims, which violated the Federal Trade Commission Act.

For guidance on helping consumers who may have questions about this order, access ACA International’s Know My Debt website and share the link with consumers and clients as appropriate.

Know My Debt, one of ACA’s most popular consumer education resources, features freshly updated content, ACA previously reported. You can include the link to Know My Debt on your agency’s home page and give it to collectors to share with consumers.

FCC Call Authentication Comments

The FCC’s Wireline Competition Bureau addresses two recurring statutory obligations under the Telephone Robocall Abuse Criminal Enforcement and Deterrence Act, relating to the commission’s caller ID authentication rules in a recent comment request.

While callers do not need to weigh in on this issue specifically on behalf of ACA, here are the details of the comment request. ACA and its coalition of joint industry trade groups continue to monitor the FCC’s requests and file and seek comments on behalf of the ARM industry.

First, the bureau seeks comment for its annual reevaluation of the STIR/SHAKEN implementation extensions granted by the commission for implementation of the STIR/SHAKEN call authentication framework. Second, the bureau seeks comment for its first triennial assessment of the efficacy of the STIR/SHAKEN call authentication framework as a tool in its work combating illegal robocalls.

The TRACED Act requires the FCC to assess burdens and barriers to the STIR/SHAKEN implementation and at least once a year reevaluate and potentially revise any extensions granted to regulated entities on the basis of undue hardship.

The comment request focuses on implementation extensions for small voice services providers and for providers unable to obtain a Service Provider Code token necessary to participate in STIR/SHAKEN.

In September 2020, the commission granted a two-year extension for all small voice service providers, defined as “a provider that has 100,000 or fewer voice service subscriber lines.” Under this extension, small voice service providers were given until June 30, 2023, to implement STIR/SHAKEN. The FCC seeks comment on whether small voice service providers face unique challenges in implementing STIR/SHAKEN, among other topics.

For more information on the proposed rulemaking, click here.

Do you have an item to submit for the Regulatory Recap? Share it with us at [email protected], Attn: Katy Zillmer.

If you have executive leadership updates or other member news to share with ACA, contact our communications department at [email protected]. View our publications page for more information and our news submission guidelines here.





This site uses cookies. By continuing to use our site, you are agreeing to our use of cookies. Review our Privacy Policy for more information. You may change your preferences on how cookies are stored by reviewing the settings on your browser.

The content on this site is presented for educational, general reference, and informational purposes only; is not intended to serve as legal or other advice; is not intended to be a full and exhaustive explanation of the law in any area; and should not replace the advice of your own legal counsel. By continuing to use our site, you are agreeing to the legal disclaimers in our Terms of Use. Review our Terms of Use for more information.

Friendly Reminder

Get continued access to ACA International’s wide array of resources, which can help you become more profitable, compliant and successful.

Renew your membership today to take advantage of tools you won’t find anywhere else:

  • Discounts on seminars, products, services and events
  • Resources to strengthen your compliance department
  • Industry-specific risk management products and services
  • Participation in ACA’s online community, The Hub
    Members-only website content
  • Professional development and training opportunities, and so much more!

If you have completed your renewal, please disregard this reminder.