In this podcast, we examine the compliance challenges arising from the provision of the CFPB's proposed debt collection rule that allows collectors to leave a limited content phone message that would not violate the FDCPA's third party disclosure prohibition. In addition to the requirement for a collector to leave the name of a natural person for the consumer to contact, we discuss the proposal's prohibition on leaving the collector's name, the CFPB's rationale for the prohibition, potential state law concerns, and implications for first party collections.

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