The Consumer Bankers Association (CBA) has filed a letter commenting on the CFPB’s proposed debt collection rule. Ballard Spahr served as counsel to the CBA in preparing the comment letter.
In the letter, the CBA urges the Bureau to make various revisions and clarifications to the proposal, including the following:
- Taking the following steps to remove any uncertainty about the potential application of the final rule to creditors: (1) rely solely on the Bureau’s FDCPA authority for all provisions of the final rule, (2) include an explicit statement in the final rule that it is not intended to apply, and should not be applied, to creditors and servicers not covered by the FDCPA, and (3) state that the definition of “debt collector” in the final rule is not intended to expand the FDCPA’s coverage to creditors and servicers.