CFPB extends applicable dates of its medical debt advisory opinion

Orrick, Herrington & Sutcliffe LLP
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On November 21, the CFPB submitted a joint status report regarding two cases, noting the Bureau is extending the applicable date of its medical debt advisory opinion from December 3 to January 2, 2025, an additional 30 days, in response to ongoing litigation. As previously covered by InfoBytes, plaintiffs have alleged that the CFPB violated the APA through their October 1 advisory opinion on collecting medical debts.

According to the joint status report, the extension aims to provide the court with sufficient time to rule on pending motions for a temporary restraining order and preliminary injunction filed by the plaintiffs challenging the opinion. The CFPB asserted that the advisory opinion itself does not create any binding legal obligations that the plaintiffs will need to comply with and as such, revising the applicable date will not affect legal obligations of regulated entities.

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