Debt collection

Friday afternoon surprise: the CFPB announces that the final debt collection rule will come into force on November 30 | Ballard Spahr srl

To the surprise of the collection industry, the CFPB announced last Friday afternoon that its final debt collection rule (parts I and II) will come into force on November 30, 2021 as initially planned.

Many in the industry expected the CFPB to extend the effective date to January 29, 2022, in accordance with its April 2021 proposal. In April 2021, the CFPB proposed the extension over concerns that, due to the disruption caused by the COVID-19 pandemic, stakeholders would need more time to review and implement the final rule.

In its Friday afternoon announcement, the CFPB said it determined the extension was not necessary. According to the CFPB, comments it received on the proposal were generally not in favor of an extension, with most industry commentators saying they would be ready to comply with the final rule by the 30th. November. an extension, they did not focus on whether more time was needed to implement the rule, but instead, many argued that an extension was needed to allow for a review of the rule. . The CFPB said a review of the rule as the basis for an extension was beyond the scope of the proposal and could raise concerns under the Administrative Procedure Act. He also noted that the CFPB was not precluded from reconsidering the rule at a later date.

To comply with the new rule, companies must redesign their systems, policies, procedures and compliance monitoring. CFPB’s announcement means that all companies that have based their timeline to make the necessary changes on an effective date of January 29 must now step up their efforts so that the necessary changes are completed on time to meet the deadline. November 30.

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