Stefanie H. Jackman, a litigation partner in Ballard Spahr's Atlanta office, was among the commercial credit and collections professionals asked to comment on the Consumer Financial Protection Bureau's Notice of Proposed Rulemaking (NPRM) for debt collection.

Ms. Jackman said the NPRM has potential to benefit the Accounts Receivable Management (ARM) industry, but some area where it lacks clarity need to be addressed first.

"At a high-level, the CFPB has taken the first step towards effectuating a sea change in how collections occur, seeking to transform it from one that depends mostly on traditional phone calls to one that instead relies primarily on email and text channels," Ms. Jackman said. "But a number of unanswered questions remain where the ARM industry will be well-served to comment in order to reduce ambiguity (and hopefully, litigation risk) as we journey together down this new road."

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