ACA Report Says CFPB is ‘Substantially’ Underestimating Estimates of Complying With Collection Proposals

Collection agencies are looking at significant increases in their expenses if the Consumer Financial Protection Bureau moves forward with its proposals to regulate the collection industry, according to the results of a survey conducted by ACA International.

For example, the cost to print and mail one additional page of paper with each collection notice — a statement of rights that the CFPB proposed when it published guidelines for the SBREFA meeting held back in August, will cost collection agencies $95,405 per year, according to data supplied by members of ACA International that responded to a survey request back in August. ACA sent the survey out to all 6,210 members, 446 of which responded.

The cost to adapt their software to meet the numerous proposals put forth by the CFPB with regard to maintaining and transmitting data between collection agencies and their clients would average $73,339 each, according to ACA.


For example, two-thirds of respondents indicated their software does not allow for the transmission of an individual’s military service, to determine whether that individual is an active duty service member. And 65% of respondents indicated their software does not allow for a client to confirm whether an individual was provided a statute of limitations disclosure.

When asked to detail the communication methods used to contact individuals, 99.7% of respondents said they use letters, 98.5% said they use the telephone, 31.7% said they use email, and 2.7% said they use text messages.

Roughly 75% of respondents meet the Small Business Administration’s definition of “small business,” which means they have less than $15 million in annual sales.

The conclusion reached by ACA’s whitepaper is that the CFPB “substantially underestimates the financial impact of new rules on these businesses.”



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