American Financial Services Association - This NPRM Needs a Second Opinion
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This NPRM Needs a Second Opinion

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The Consumer Financial Protection Bureau (CFPB) today announced a Notice of Proposed Rulemaking(NPRM) aimed at addressing the reporting of medical bills on credit reports. This initiative follows the CFPB’s September 2023 announcement to explore options for restricting such reporting practices.

The CFPB’s NPRM highlights the importance of accurate credit reporting that ensures both a safe and sound credit marketplace for consumers and the consumer credit industry that serves them. To achieve this worthy goal is credit reporting that enables creditors to have a comprehensive picture of a prospective borrower’s financial status so that creditors can evaluate the risk of extending credit and consumers’ ability to repay. This, in turn, protects the consumer from facing harmful financial consequences that hinder their future credit capacity and creditworthiness. However, today’s announced NPRM as implemented would not create greater certainty for either creditors or consumers.

At the same time, this also NPRM creates unnecessary confusion. On the one hand, the notice requires that legally reportable medical debt be removed from credit reports, while on the other the CFPB is taking enforcement action against creditors for not collecting enough financial information from prospective borrowers, such as their monthly expenses for groceries and what they payout for childcare.

While we appreciate the Bureau’s effort to use traditional rulemaking in this process, rules of the road that send conflicting messages are unhelpful and counterproductive.  Rulemaking that puts in place clear rules that protect consumers and ensure a safe and sound marketplace with greater access to credit for all consumers would best serve all stakeholders in this process.

This NPRM Needs a Second Opinion
Jun 11, 2024

The Consumer Financial Protection Bureau (CFPB) today announced a Notice of Proposed Rulemaking(NPRM) aimed at addressing the reporting of medical bills on credit reports. This initiative follows the CFPB’s September 2023 announcement… Read the rest

Featured Business Partner | Fortegra
Jun 04, 2024

The featured Business Partner for the month of June is Fortegra.

For more than 40 years, Fortegra and its subsidiaries have delivered risk management solutions that help people and businesses succeed in the face of uncertainty.

Our diverse

Read the rest

The CFPB Just Doesn’t Get It
Jun 03, 2024

Today, the Consumer Financial Protection Bureau finalized a proposal to create a nonbank registry related to enforcement matters. The final rule requires certain nonbank entities to register information about their company and certain… Read the rest

News From Our Members | Alfa Systems 6 moves ahead with its fourth pillar, Scalability
May 28, 2024

Alfa, a leading provider of enterprise software for the automotive finance industry, has announced the release of Scalability, the fourth of six releases that make up Alfa Systems 6 – a breakthrough iteration of its Alfa Systems software… Read the rest

Despite SCOTUS Ruling, CFPB Oversight Needed
May 16, 2024

Today, the U.S. Supreme Court handed down its ruling in the much-anticipated Consumer Financial Protection Bureau (CFPB) v. Community Financial Services Association of America (CFSA) case that challenged the CFPB’s independent funding… Read the rest

Capital Challenges | 2024 Independents Conference & Expo
May 02, 2024

As our industry adapts to the evolving financial and economic landscape while seeking to capitalize on emerging opportunities, broadening the pool of capital providers and expanding funding options is top of mind.

Join our all-star panel… Read the rest

Updating the Economic Outlook
May 02, 2024

The Federal Reserve announced Wednesday that it would leave its short-term interest rate target unchanged at 5.25 percent to 5.5 percent. The news was not a surprise. That the Fed would remain on hold was considered a near certainty in the weeks… Read the rest

News From Our Members | New PayNearMe Research Reveals Growing Importance of Customer Experience in Loan Repayment
May 01, 2024

In PayNearMe’s new study “Consumer Trends Driving the Future of Loan Payments,” we reveal that challenges in the loan repayment process and poor payment experiences jeopardize customer loyalty and retention for lenders.… Read the rest

Featured Business Partner | Flagstar Bank
May 01, 2024

The featured Business Partner for the month of May is Flagstar Bank.

Flagstar Bank is a leading regional bank headquartered in NY with over $100 billion in assets and a robust Corporate Banking Division. Within Corporate Banking, we focus … Read the rest

AFSA Touts Consumer Privacy Rights
Apr 25, 2024

Last week, AFSA’s State Government Affairs team sent a joint comment letter to the California Senate Judiciary Committee regarding Senate Bill 1076 and consumer privacy rights in the state.

In the letter, AFSA expresses support for SB 1076… Read the rest

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