On July 27, 2022, the Consumer Financial Protection Bureau (CFPB)added 15 new questions and answers to its Debt Collector Rule FAQs. The expanded sections include: Prohibitions on Third-Party Communications; Electronic Communication; Electronic Communication: Opt-out Notice; and Unusual or Inconvenient Times or Places.
On June 29, the CFPB issued an advisory opinion affirming that federal law prohibits debt collectors from charging “pay-to-pay” fees. These charges, commonly described by debt collectors as “convenience fees,” are imposed on consumers who want to make a payment in a particular way, such as online or by phone. The advisory opinion is based on language in Section 808 of the Fair Debt Collection Practices Act (FDCPA), which prohibits debt collectors from collecting any […]
On October 1, 2021, the Consumer Financial Protection Bureau (CFPB) published a series of 27 Frequently Asked Questions covering the Fair Debt Collection Practices Act and Regulation F. Regulation F is effective on November 30, 2021.
On July 30, 2021 the Consumer Financial Protection Bureau announced that the two final rules (Regulation F) issued under the Fair Debt Collection Practices Act (FDCPA) will take effect as planned, on November 30, 2021. The CFPB issued a proposal in April 2021 that, if finalized, would have extended the effective dates to January 29, 2022. The CFPB has now determined that such an extension is unnecessary. Following this announcement, the CFPB will publish a formal notice […]
Massive revisions to the Fair Debt Collection Practices Act (FDCPA), and its implementing Regulation F, have been unfolding over the past few years. The final rule is effective on November 30, 2021, although the CFPB has proposed to extend the effective date to January 29, 2022. Many banks want to operate under the assumption that the FDCPA and Regulation F do not apply to their operations. We have steadfastly maintained that the law and regulation […]