Debt Buying Giant Files More Comments About Proposed Rule, This Time Focusing on Changes to Model Validation Notice

A new series of comments have been filed about the Consumer Financial Protection Bureau’s proposed debt collection rule from individuals in the credit and collection industry, this time focusing on the proposed model validation notice.

The comments all appear to be originating from the same source, possibly the same company that helped generate the last spate of comments that endorsed some of the changes being proposed by the CFPB.

About a dozen comments — all containing virtually the exact same language — were published yesterday seeking, among other things, a safe harbor for collectors using the model validation notice while also incorporating state-mandated disclosures, and requesting several additions to the tear-off form that consumers can use to dispute a debt. Those additions are:

  • Check a box that a payment is enclosed. Many more consumers respond to a validation notice with a payment than a dispute, and the tear off form should make it easy for consumers to submit a payment and move towards resolving their debt obligation.
  • Differentiate between a dispute and an inquiry. An inquiry is very different from a dispute or complaint, and without providing such differentiation, it will be harder for collectors to appropriately address the consumers concern.  
  • Provide the best contact information to be reached at. This will help enhance communication between the consumer and collector, and will help collectors address any disputes, inquiries, or requests for payment plan options from consumers.  
  • Respond to the tear off sheet through the collectors website. Allowing consumers to complete the tear off sheet online bolsters the use of new technology for the consumer, which may be easier and more immediate for many consumers than using postal mail. 

Among those filing the same comments yesterday were Peter Balsino, a state managing attorney for Encore Capital Group, Molly Sauser, a talent recruiter at Midland Credit Management, Diana Loberg, an account manager at Encore, and Jim Talmage, an account manager with Midland.

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