The comment period starts running tomorrow when the Advance Notice of Proposed Rulemaking (ANPR) on debt collection issued by the CFPB will be published in the Federal Register.  Comments on the ANPR will be due by February 10, 2014.  

We have prepared a legal alert summarizing the ANPR.  In addition, on November 25, 2013, from 12 p.m.to… Continue Reading

The Advance Notice of Proposed Rulemaking (ANPR) on debt collection issued by the CFPB earlier this week solicits comments on an array of issues relating to the debt collection practices of third-party debt collectors and debt buyers as well as those of creditors collecting their own debts. Based on the CFPB’s discussion of its rulemaking authority in the ANPR’s supplementary information, in proposing debt collection rules, the CFPB can be expected to rely on a wide range of authority, including its new authority to issue substantive rules under the Fair Debt Collection Practices Act and its Dodd-Frank authority to prescribe rules prohibiting “unfair, deceptive, or abusive” acts or practices. … Continue Reading