It has been reported that the SBREFA panel for the CFPB’s debt collection rulemaking met last week with small entity representatives (SER). In anticipation of convening the panel, the CFPB issued an outline of the proposals it is considering on July 28, 2016.
According to the report, SERs must submit their written comments by September 9, 2016. Assuming the CFPB does not plan to hold any further meetings with SERs, the next step will be for the panel to issue its report to the CFPB on the input received from the SERs. The panel has 60 days to submit its report from the date it is considered to have “convened.” Accordingly, it appears that the report will be due in October 2016. However, it will not become public until the CFPB issues its proposed rule. Based on prior experience with other SBREFA panels, we would expect the proposed rule to be issued during the first six months of next year.