Shareholder Sara Costanzo
recently attended the American Financial Services Association (AFSA)’s 2021 Annual Meeting
. Sara participated as a panelist to discuss debt collection and the CFPB’s Regulation F. In anticipation of the effective date of Regulation F on November 30, 2021, we want to share some key takeaways from her panel to help prepare for this new Rule.
While Regulation F is intended for third-party debt collectors, there is cause for creditors to take pause. The new debt collection regulations that are going into effect can raise operational issues for data transmission. Additionally, work standards and expectations that creditors have of third-party collections and vendors may need to be adapted to remain compliant. Beyond third-party debt collection, there is concern that down the road, call limitations (and other restrictions) may be implemented in the world of first-party and creditor communications with consumers.
Caution is key. As with any new regulation, start out slowly and make sure express authorization is provided under Telephone Consumer Protection Act (TCPA)
before using and passing points of contact on to third-party debt collectors and vendors. Here are some simple tips to keep in mind:
This blog is not a solicitation for business and it is not intended to constitute legal advice on specific matters, create an attorney-client relationship, or be legally binding in any way.