Bedard Discusses New Validation Period Requirements

The model validation notice represents a complete top-down overhaul of the validation notice that debt collectors have been sending since the Fair Debt Collection Practices Act was enacted back when disco was king. Among two of the major changes to the information that collectors will now be required to include in their validation notices are covered in the latest episode of “You Wanted a Rule, You Got a Rule.” In this episode, John Bedard of Bedard Law Group walks through Section 1006.34c(3) of Regulation F, which covers information about consumer protections that are required to be communicated as part of the validation notice. And collectors will see that not only do they have to get more specific, they are going to have to include a link to the Consumer Financial Protection Bureau in the notice, too.

This section includes six pieces of information, many of which will be familiar to collectors. The part that are new compliance wrinkles, as Bedard points out in the episode, are a new requirement that collectors specify the date in which the validation period ends. In the past, collectors just had to give a 30-day window from the time the letter was received. Now, collectors will have to specifically pick a date to let consumers know when the validation period — in which consumers can dispute the validity of a debt — expires. “It’s no longer adequate to tell the consumer that they have to dispute within 30 days of receipt of the letter,” Bedard said. “Instead, the collector is going to put the date that the validation period expires on the letter.”

The other new piece of information that will have to be required in validation notices — whether a collector opts to use the model validation notice or not — is information “that informs the consumer that additional information regarding consumer protections in debt collection is available on the Bureau’s website at www.cfpb.gov/debt-collection.”

Check out all the episodes in the series here: You Wanted a Rule, You Got a Rule. You will also find links on that page to subscribe to the audio version of the series through Apple Podcasts, Google Podcasts, and Spotify. Like what you see? Be sure to reach out to John and let him know!

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