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CFPB Seeks to Delay Effective Date of Debt Collection Final Rules (Regulation F)

cfpbOn April 7, the Consumer Financial Protection Bureau issued a Proposed Rule that would postpone the effective date of the Debt Collection Final Rules, Part 1 and Part 2, by 60 days, from Nov. 30, 2021, to Jan. 29, 2022.

The CFPB cites the “disruption caused by the global COVID-19 pandemic” as the impetus for the Proposed Rule, which if finalized would “afford stakeholders additional time to review and, if applicable, to implement the Debt Collection Final Rules.”  The CFPB notes that because of the short delay proposed, any reduction in benefits provided to consumers should be minimal.

The CPFB advises that while “debt collectors could choose to comply with the rules’ requirements and prohibitions before the effective date,” the safe harbors would not yet apply.  

The CFPB specifically requests comment on:

  1. Whether the effective date should be extended;
  2. Whether 60 days is an appropriate timeline;
  3. Whether the original effective date should be kept for all or some of the safe harbors considering, for example, the costs and benefits they may provide to debt collectors;
  4. Whether the extension may reduce access to consumer financial products and services; and
  5. Any additional information relating to “potential benefits, costs, and impacts of this proposed rule.”

Public comments must be submitted on or before the 30th day after the Proposed Rule is published in the Federal Register.

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Eric Rosenkoetter is a principal at Maurice Wutscher LLP, where he provides counsel to businesses and consumer financial services firms nationwide. For many years, he has focused his practice on various aspects of financial services law. As a litigation attorney, he has conducted every aspect of the litigation process, including countless depositions, motion proceedings, bench and jury trials, and appeals in various courts. In addition, he has significant experience as a compliance and transactional attorney, providing strategic, business growth, legislative, compliance and regulatory advice to national corporations and trade associations. For example, he has drafted consumer contracts and disclosures designed to state-specific statutory requirements, and developed “Best Practices” guides and state-by-state compliance grids, for national financial services companies. He also conducted research and crafted a metrics report for a national trade association with analysis designed to counter the claims of advocacy groups. Eric’s experience also includes working for a national corporation as Executive Counsel, Chief Compliance and Ethics Officer, and Director of Legislative Affairs, and as a federal lobbyist and Director of Government and Public Affairs for a national financial services trade association. In the government sector, Eric presided over approximately 6,000 state administrative hearings, served as a staff attorney for the Missouri Senate, and handled litigation in 33 counties as a regional managing attorney. Eric frequently speaks to audiences on topics relevant to the financial services industry including regulatory compliance, data privacy law and related advocacy initiatives. For more information, see