In this issue: Time is money, so what are you waiting for? See how the CFPB's rule changes apply to providers, and how a court ruling puts commons sense back on the table, plus links from around the web!
Once an organization has decided to use an agency to collect on its bad debt, it must decide when it should start placing its accounts with the agency. While there are many pieces to consider for its own placement process – what information to collect, what information to turn over, how to place accounts securely, among a multitude of other factors – one of the most critical policies, and one which will have a definitive impact on its collections results is when to place those accounts. With this in mind we will explore four key reasons to get placements in sooner than later.
On May 7, 2019, theConsumer Financial Protection Bureau(CFPB) published its highly anticipatednotice of proposed rulemaking(know as an “NPRM”) under the Fair Debt Collection Practices Act (FDCPA). While the actual rules are intended to apply only to third-party debt collectors covered by the FDCPA, first-party creditors, servicers and providers will certainly be affected by these changes as well.
With this NPRM document weighing in at over 500 pages, we've outlined a brief summary of the major proposed rules that will have a definitive effect onproviders,creditorsandALL OF OUR CLIENTS:
Courts are finding that when consumers sign a contract with a company and establish a bargained-for exchange they can no longer revoke consent to be contacted. This has broad implications for the collections industry as it relates to an agency’s ability to contact consumers on behalf of the clients they serve.
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