I recently spoke at two different conferences for credit unions. During both speeches, I asked the audiences (approximately 125 people at one and 105 at the other) if they were aware that the CFPB was considering rules to regulate first-party collections. I also asked if they were aware of the current proposed rules for both first-party and third-party collections, which include rules on debt substantiation and transfer of data. Only five to 10 people raised their hands at each session. 

The CFPB’s proposed debt collection rulemaking has been in the works since November 2013, when the Advanced Notice of Proposed Rulemaking was posted. The ANPR was a series of more than 160 questions, aimed at both the credit/collections industry and individual consumers. A period of time was allowed for comments and more than 10,000 flowed in.

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