The comment period closed yesterday on a Request for Information released by the Consumer Financial Protection Bureau related to the creation of a task force that would be charged with harmonizing and modernizing federal consumer laws. While there weren’t many comments filed, there were many strong opinions and some interesting data points about debt collection that were submitted.
Many of those who filed comments, especially those from consumer advocacies took the CFPB to task for not extending the comment period or delaying the RFI because of the coronavirus pandemic. “We find it remarkable that the Consumer Financial Protection Bureau (CFPB) would devote considerable time, effort and money to reevaluate consumer protection laws in the midst of an unprecedented, nationwide medical and financial crisis,” wrote Ruth Susswein of Consumer Action. “It should not be necessary to point out that now is precisely the time for the Consumer Bureau to laser-focus its attention on consumer protection, education, outreach and oversight during this pandemic, making every effort to prevent financial harm for the most vulnerable among us.”
Others took the opportunity to remind the CFPB that they want the leadership structure of the agency changed, even if that was not part of the RFI and would be well outside the Task Force’s — and the CFPB’s — purview. From the Credit Union National Association: “While not within the CFPB’s authority to change, CUNA believes any meaningful attempt to address the Bureau’s ability to carry out its mission should begin with the structure of the Bureau itself. In that regard, the current structure — with a single director — gives too much authority to one person and does not provide meaningful oversight and accountability. It ultimately fails consumers.”
Saving the best for last, TrueAccord submitted its own comment, which included an infographic about the benefits of using email in debt collection. The company recommended that the agency “consider accelerating” the timeline for its Notice of Proposed Rulemaking related to debt collection. The data in the infographic is meant to support the company’s assertion that using digital collection in debt collection “simplifies the lives of consumers, puts them in control of their finances, and offers flexible payment options.”
The infographic noted, for example, that 84% of the debts resolved by TrueAccord are done so without the consumer ever speaking with a live representative, and 25% of the visits to its website are made outside of the contact hours allowed under the Fair Debt Collection Practices Act.
