The State Attorneys General from 30 states and the District of Columbia submitted a comment letter to the CFPB on February 28, 2014, urging the CFPB to “adopt well-tailored, comprehensive, and balanced rules” that will apply to “all persons engaged in the collection of consumer debts” which would presumably include both first and third-party collectors.

Industry participants are strongly encouraged to take note of the 30 signatories and the broad range of topics that the letter covers as it provides a preview into what a more aggressive FDCPA rulemaking would look like and the kinds of business practices that regulators – both federal and state attorneys general – could be seeking in their supervisory and enforcement actions.