Top ARM professionals provide analyses and insights into the finer points of the proposed rule.
While the Consumer Financial Protection Bureau’s long-awaited proposed rule concerning the debt collection industry was issued two months ago, there’s still time to impact the final form by submitting comments to the bureau. To help its members understand the finer points of the rule, ACA International launched a first-class education program highlighted by webinars, presentations and numerous news articles and letters. Nevertheless, there’s more to come.
In the latest episode of ACA Cast titled, “The CFPB’s Proposed Rule: Peeling Back the Layers,” Jack Brown III, an attorney and president of Gulf Coast Collection Bureau, leads an informative panel discussion outlining important highlights of the proposed rule. Featured panelists include Eileen Bitterman, a compliance officer and shareholder with Weltman, Weinberg & Reis, and Tim Collins, the chief compliance officer with TrueAccord.
In its current state, the proposed rule includes:
- Certain disclosures, such as an itemization of the debt and plain-language information about how a consumer may respond to a collection attempt, including by disputing the debt.
- Methods by which debt collectors may lawfully use newer communication technologies, such as voicemails, emails and text messages.
- Methods by which collectors may provide required disclosures electronically, for example, by email or text message.
- Call frequency limits of no more than seven attempts by telephone per week; prohibiting call attempts within 7 days of a telephone conversation.
- Out-of-statute debt collection, by prohibiting suits and threats of suit on time-barred debts and requiring communication with the consumer before credit reporting.
Tune in to hear Brown, Bitterman and Collins discuss some of the important aspects of the rule and ways implementation could impact the daily functions of accounts receivable management industry professionals.
The CFPB its proposed rule was published in the Federal Register on May 21, 2019, meaning public comments are due by Sept. 18, 2019.