On Thursday, November 3, 2016, I joined a group of colleagues for a meeting with the CFPB to discuss its proposed rules for third party debt collection. I was one of four attorney members of the National Creditors Bar Association in attendance. Joining us were representatives from the American Collectors Association and the Debt Buyers Association. The CFPB had invited us to meet with them following their Small Business Review Panel discussion a couple of months earlier.
The CFPB asked each of the industry groups to speak about the proposed rules’ impact on their respective industries. Some of our common concerns included the excessive number of notices and disclosures the proposed rules would require, the limits on communications with consumers, and