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Pro-Industry Comments Submitted To Show Support for Proposed Debt Collection Rule

A number of pro-industry comments supporting the Consumer Financial Protection Bureau’s proposed debt collection rule were published yesterday, including one from a conservative think tank.

The Competitive Enterprise Institute supported much of what the CFPB did in the proposed rule, even going as far as to urge the agency to “proceed carefully” when placing call frequency limits on accounts and disclosure notices when attempting to collect on time-barred debt. The CFPB should be commended for “attempting to bring greater legal certainty to the use of modern communication methods by collectors, to provide model disclosure notices for consumers, and to create reasonable safe harbors for industry,” the CEI wrote in its comment.

Along with its support of the provisions of the proposed rule, the CEI even used its comment to take a swing at the “unreliability” of the CFPB’s complaints database and the “severe statistical and economic problems” it has.

Also filing a comment was Ranjan Dharmaraja, the chief executive of Quantrax, a solutions provider to the credit and collection industry. Dharmaraja’s comment focused on supporting the provision that would allow collectors to send text messages to individuals when attempting to collect on unpaid debts. Acknowledging the argument that individuals could be bombarded with text messages from collectors, Dharmaraja wrote, “Do not penalize the majority of companies that want to do it right and not inconvenience the consumer. There are people who write bad checks knowingly. Do we stop all people from writing checks? Credit card fraud exists. Did we stop the use of all credit cards? No, we tackle the problem.”

Still on the topic of allowing collectors more freedom to deploy modern communication tools, Meduit, a revenue cycle management provider, also submitted a comment about the proposed rule. Meduit, which operates a number of subsidiaries, including Receivables Management Partners, LLC; PMAB, LLC, and Allied Revenue Services, LLC, expressed support for the CFPB seeking to allow collectors to use “modern communication modes,” while also seeking clarity on “new requirements for credit reporting, frequency limits including one right party conversation per week, and aspects of the model validation notice to better account for various types of debts and the nature and size of those in the industry.”

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