While the calling restrictions are sure to get the most publicity from the CFPB’s new debt collection rule, a number of the less discussed aspects of the rule may present just as many operational challenges. For instance, the CFPB’s prohibition on the sale or transfer of certain types of debt, as well as the record retention requirements in the rule will likely present a number of hurdles of their own. During this webinar we will provide an overview of some of the additional rules that we have not previously discussed in prior working sessions and discuss some of the nuances and complexities of those requirements.
Whether you are a third-party debt collector whose entire business will be subject to the rule, a loan servicer who is only considered a debt collector for certain loans, or a first party creditor interested in establishing best practices based off of the CFPB’s guidance, join us to learn more about how these additional restrictions and obligations will impact your business.
- Revise your policies and procedures and compliance monitoring to avoid transfers of paid, settled, or discharged debts unless they meet the narrow exceptions
- Begin developing your duplicate dispute response process
- Debt collectors have a 3 year record retention requirement from (1) the date of the call for phone calls, and (2) the date of the last collection activity for everything else. This could in some situations be longer than the records retention requirements in other statutes (e.g. RESPA)