After 35 episodes and nearly eight hours of in-depth analysis, we have reached the end of the line. The series finale of “You Wanted a Rule, You Got a Rule.” In the last episode of the series, John Bedard of Bedard Law Group breaks down the last three sections of Regulation F — Sections 1006.100, 1006.104, and 1006.108. These sections might not have the bells and whistles like many of the other sections of the Consumer Financial Protection Bureau’s debt collection rule, but they are just as important.
For example, Section 100 requires debt collectors to maintain records that prove they are complying with Regulation F and the Fair Debt Collection Practices Act. Without that, it might be hard to make a case if the CFPB ever comes knocking with a Civil Investigative Demand. Bedard notes in the episode that Regulation F requires collectors to hold on to those records for three years before thinking about getting rid of them. The section does not require collectors to create new documents or evidence, Bedard points out, but to maintain the documents and evidence it does create.
Section 104, meanwhile, is a housekeeping section aimed at ensuring that nothing contained in Regulation F is intended to have any impact on state laws, and Section 108 gives states the option to ask the CFPB for permission to be exempted from federal enforcement of Regulation F in that state.
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!