On April 17, Tom Pahl, managing regulatory counsel for the Consumer Financial Protection Bureau Office of Regulations, spoke at ACA International’s Washington Insights Conference about the CFPB’s debt collection rulemaking. According to Pahl, the CFPB currently is focusing on four debt collection related topics for its proposed rulemaking:
- Communication issues;
- Data integrity and information issues;
- Informed consumer issues; and
- Regulation of first-party collections issues.
Pahl described how the CFPB is incorporating data from consumers into the rulemaking process. For example, the CFPB sent out a survey to consumers in an effort to obtain feedback from consumers on typical experiences with debt collectors and changes consumers would like to see in the debt collection industry. Pahl did emphasize that consumer data was only one piece of data the CFPB considers in forming its rulemaking agenda.
The CFPB also has been testing disclosure documents with consumers across the country. The CFPB is considering developing a model validation notice that debt collectors could use to shield themselves from liability.
While Pahl did not give an expected time period for the proposed rulemaking, it is expected that the results will not be announced until the end of 2015.