No federal agencies have promulgated any significant regulations under the US Fair Debt Collection Practices Act (“FDCPA”) since its passage in 1977. Until the Dodd-Frank Act became effective, no federal agency even had the authority to do so. Courts were free to fashion their own standards and interpretations of the FDCPA, resulting in inconsistent standards and a maze of differing interpretations. Fortunately for entities seeking simple, practical and uniform standards for FDCPA compliance in the modern age, the Consumer Financial Protection Bureau (the “CFPB”) issued its proposed Regulation F under the FDCPA on May 7. In this Legal Update, we summarize the CFPB’s proposed debt collection rulemaking and describe the consequences for entities engaged in collecting consumer-purpose debts, summarizing some of the most significant developments that FDCPA-regulated entities should review when considering whether to provide comments to the CFPB.
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