The Consumer Financial Protection Bureau on Friday released a new resource related to its debt collection rule, this one aimed at helping smaller collection agencies comply with the rule once it goes into effect this November.
At a brisk 87 pages, the Small Entity Compliance Guide to the Debt Collection Rule is far easier to digest than either the 653 pages that constituted Phase 1 of the Debt Collection Rule or the 354 additional pages that were published when Phase II was released last month. The Small Entity Compliance Guide appears to mostly deal with Phase I of the debt collection rule, noting that the guide does not discuss the December portion unless specifically noted. The guide also appears to be related to the compliance aids requirements under the Small Business Regulatory Enforcement Fairness Act (SBREFA).
The guide includes a detailed summary of the provisions of Phase 1 of the debt collection rule while also highlighting “key interpretations and clarifications” of the Fair Debt Collection Practices Act.
Companies may choose to start complying with the requirements of the rule before it goes into effect on November 30, but “to the extent the Rule establishes a bona fide error defense, safe harbor, or a presumption that certain conduct complies with or violates the Rule, those defenses, safe harbors, and presumptions are not effective” until the rule goes into effect.
While no new ground is broken in the guide that the CFPB released, it is a handy reference guide to the provisions of the rule and what will be require of collection agencies once the rule goes into effect.
EDITOR’S NOTE: AccountsRecovery.net has published a comprehensive resource for the debt collection rule, including comments and perspective from more than 20 compliance experts. Check it out here.
