CFPB Publishes Compliance Aids in Anticipation of New Debt Collection Final Rules Becoming Effective

Troutman Pepper

Troutman Pepper

Last month, industry saw the Consumer Financial Protection Bureau (CFPB) issue a number of compliance aids in anticipation of two CFPB Debt Collection Final Rules becoming effective on November 30. On October 1, the CFPB issued the Debt Collection Rule FAQs, which contained questions and answers pertaining to limited-content messages and telephone call frequency.

Then, on October 29, the CFPB expanded the FAQs to include questions and answers to assist debt collectors in providing consumers with “validation information.” The expanded FAQs also include a section specifically addressing the special rule for providing validation information for certain residential mortgage debt. On this same day, the CFPB issued a new compliance aid titled, “Debt Collection Rule: Disclosing the Model Validation Notice Itemization Table.” This new compliance aid:

  • Discusses the validation information contained within the model validation notice’s itemization table;
  • Outlines how a debt collector may complete the itemization table; and
  • Includes example itemization tables for different debt types.

In addition to the above resources, the CFPB on October 18 issued a Spanish translation for the model validation notice. Use of this document “by a debt collector who provides or has provided a consumer with the model English-language validation notice provides a safe harbor for the Rule’s requirement that any translations be complete and accurate.”

With the effective date of the new CFPB Debt Collection Final Rules fast approaching, we encourage industry to review and assess these recent compliance aids to help inform their debt collection compliance strategies. All of the above resources, along with additional resources for the new final rules, may be accessed on the CFPB’s compliance resources webpage for debt collection.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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