Update on the CFPB's Proposed Debt Collection Rule
Our podcast looks at industry and consumer comments and perspectives on key issues, including the proposal’s potential implications for creditors collecting their own debts through UDAAP/UDAP and state collection laws, its approach to electronic communications and “meaningful attorney involvement,” and whether a final rule should address information transfers and file reviews or collecting time-barred debt. We also share our predictions for what a final rule will contain and suggestions for using the proposal to reduce risk in first-party collections.
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