On March 6, AFSA commented on a proposed CFPB survey. The survey asks for consumers’ experience with debt collection and feedback on proposed disclosure forms. The CFPB first issued its request for approval in June 2017, then again in November 2017, but withdrew the latter request. Earlier this year, the CFPB re-published the survey for comment.
AFSA wrote that it supports the CFPB’s intent to begin a debt collection rulemaking, but asked that the survey not proceed as proposed.
The letter stated, “First, while we recognize the CFPB’s need to inform its debt collection rulemaking with data, conducting this survey is premature. Before testing disclosure forms with consumers, the CFPB should release the forms for notice and comment. After gathering comments and making changes to the forms based on those comments, then the CFPB could test the forms with consumers.”
AFSA also said that substantial changes need to be made to the survey itself. For example, AFSA objected to the style of many of the questions, writing, “They do not appear related to the particular communications at issue and the effectiveness of those communications. Rather, they appear to collect attitudinal data of consumers, which is not relevant to the effectiveness of the communications the CFPB seeks to sample.”
On March 6, AFSA commented on a proposed CFPB survey. The survey asks for consumers’ experience with debt collection and feedback on proposed disclosure forms. The CFPB first issued its request for approval in June 2017, then again … Read the rest
Just in time for March Madness, the AFSA Education Foundation was able to secure a full-page article in Rebound Magazine – a publication about basketball players for basketball players and their fans. This opportunity came through… Read the rest
Join us on March 14, 2019, at 2 p.m. ET for Instant Funding through Push Payment Technology, presented by REPAY.
In today’s fast-paced and highly digital world, it’s important for lenders to stay relevant by offering flexible… Read the rest
Notwithstanding press reports to the contrary, thoughtful review of data about the state of vehicle finance demonstrates that the market has grown in recent years with continued participation across the credit spectrum. The vehicle finance… Read the rest
Each year since the mid-1980s, the AFSA Education Foundation offers two important enrichment programs for employees of member companies. The first program is THE EDGE, an acronym for Education, Development, Growth, and Enrichment. Designed… Read the rest
Join us on March 14, 2019 at 2 p.m. ET for Instant Funding through Push Payment Technology, presented by REPAY.
In today’s fast-paced and highly digital world, it’s important for lenders to stay relevant by offering flexible … Read the rest
AFSA would like to welcome the following new members to the association:
CU Direct connects more than 16,000 car dealerships to 1100 credit unions for auto loan application, transmission and funding. CU Direct provides full circle lending… Read the rest
AFSA staff and other trade associations met with the Federal Communications Commission (FCC) this week and last week to discuss the Telephone Consumer Protection Act (TCPA).
The group of trades met with staff from the FCC’s Consumer… Read the rest
Stephen Moore, author, economist and former Wall Street Journal Editorial Board member, headlines the second annual AFSA Law and Compliance Symposium, March 5-7 in Ft. Lauderdale, Fla.
Moore today is the Distinguished Visiting Fellow,… Read the rest
A high-ranking executive of the Consumer Financial Protection Bureau will address AFSA’s second annual Law and Compliance Symposium on March 5, the first day of the conference. John McNamara, the CFPB’s Assistant Director… Read the rest
