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CFPB: Effective Date for Debt Collection Final Rules is Nov. 30, 2021


CFPBThe Consumer Financial Protection Bureau (CFPB) announced on July 30 that it will be withdrawing its earlier proposal to extend the Regulation F effective date by 60 days. Thus, the original effective date of Nov. 30, 2021, will remain.

The proposal to extend the date, discussed here, was intended to address the “disruption caused by the global COVID-19 pandemic” and “afford stakeholders additional time to review and, if applicable, to implement the Debt Collection Final Rules.” According to the CFPB, “[t]he public comments generally did not support an extension.”

While the comments from industry generally indicated readiness by the original effective date, a number of consumer advocates pushed for an extension for the wrong reasons:

Although consumer advocate commenters generally supported extending the .effective date, they did not focus on whether additional time is needed to implement the rules. The alternative basis for an extension that many commenters urged, a reconsideration of the rules, was beyond the scope of the NPRM and could raise concerns under the Administrative Procedure Act.

However, the CFPB noted that “[n]othing in this decision precludes the CFPB from reconsidering the debt collection rules at a later date.”

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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 https://mauricewutscher.com/attorneys/eric-rosenkoetter/

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