On July 28, 2016, the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) issued its outline of proposals under consideration for the regulation of debt collection. This 117-page release, entitled “Small Business Review Panel for Debt Collector and Debt Buyer Rulemaking: Outline of Proposals Under Consideration and Alternatives Considered” (“Outline”), was announced in connection with the CFPB’s field hearing on debt collection in Sacramento, California (“Field Hearing”). The Outline is in preparation for the convening of a Small Business Regulatory Enforcement Fairness Act Panel (“SBREFA Panel”), a process mandated by the Dodd-Frank Act for CFPB rules anticipated to have a significant impact on small businesses. The release kicks off the next step in the CFPB’s promulgation of a final rule, the SBREFA Panel process. The SBREFA Panel meetings are scheduled for late August 2016.

In his remarks at the Field Hearing, CFPB Director Richard Cordray summed up the work ahead for the CFPB: “Today we are considering proposals that would drastically overhaul the debt collection market.” Given the ambitious sweep of this statement, it is important to carefully examine, and fully understand the scope of, the Outline and related issuances.