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American Financial Services Association

AFSA Comments on Debt Collection Disclosures

AFSA Comments on Debt Collection Disclosures

This week, AFSA commented on the Consumer Financial Protection Bureau’s (CFPB) proposed rulemaking on time-barred debt disclosures. Specifically, the proposed rule would require a debt collector collecting on a debt (that the debt collector knows or should know is time-barred) to disclose: (1) that law limits how long the consumer can be sued for a debt, and (2) if the debt collector’s right to bring legal action against the consumer can be revived under applicable law.

In the letter, AFSA commended the CFPB for clearly distinguishing between creditors and debt collectors. The proposed rule applies only to debt collectors, though it will affect creditors and their customers. AFSA is concerned that some of the requirements in the proposed rule could result in consumer confusion and suggested several changes be incorporated.

The CFPB hopes to finalize its broader debt collection rule by the end of the year, though this proposed rule on time-barred debt disclosures may be finalized later.

August 6th, 2020 by

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