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I’ll Say What She Said

It’s hard to believe this is an accident or a coincidence, but consumers are starting to file very similar comments over the Consumer Financial Protection Bureau’s proposed debt collection rule.

To date, there have been 71 comments filed about the proposed debt collection rule, most of them by consumers. But, for the most part, the comments were unique — despite being against the changes proposed by the CFPB — the individuals filing the comments did so using their own experiences and language.

However, three new comments were posted yesterday that all had the same suggestions for the CFPB. Each of those comments — from Linda Sherry, Tim Dalton, and Geri Duggan, made the following suggestions:

The proposed rule:

– Allows too many calls up to seven attempted calls per debt, per week! Instead, the rule should allow one conversation a week and two attempts per consumer, not per debt. 

– Allows unlimited texts, emails and direct messages without consent! Instead, consumers should choose how they want to be contacted about a debt, and no electronic communication should be allowed without prior consent. Collectors should be limited to one contact per week per consumer, not per debt. 

– Protects deceptive practices by collection attorneys! Instead, the rule must require that collection attorneys review original account-level documentation of the debt to ensure they are collecting the right amount from the right person.

– Allows for collection of “zombie” debt! Instead, the rule should fully ban collection of debts that are too old to sue over. 

– Permits consumer privacy violations! The rule would allow limited content voicemail, email and text messages, which could be heard or seen by others. Instead, consumer privacy should be prioritized in all messages.

I urge the CFPB to create a fair debt collection rule, not make it easier for debt collectors and their lawyers to harass and abuse consumers!

Three comments that have the exact same requests are not enough to reveal whether this is coming as a result of a coordinated effort by a consumer advocacy group. For all I know, the comments all came from the same person using different names. But it is a little too coincidental to just be brushed aside.

The comment window is open until August 19 and a huge influx of comments is expected between now and then. When the CFPB published its advanced notice of proposed rulemaking, more than 20,000 comments.

If this is the beginning of a coordinated campaign, then the credit and collection industry can now see the areas of focus that consumer groups will be targeting as they seek to persuade the CFPB to make changes to the proposed rule.

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