CFPB Updates Debt Collection Examination Procedures

Now that Regulation F has gone into effect and the industry has had time to digest all of the changes that needed to be made, it seems only fitting that the Consumer Financial Protection Bureau would update its guide detailing how collection operations are examined, to coincide with the new requirements of Reg F.

Earlier this month, the CFPB published an updated manual of its debt collection examination procedures, a bible that many in the industry use to make sure they know exactly what the CFPB is looking for.

The CFPB did not highlight any of the changes that were made to the examination manual, but just doing a quick search of the document highlights 138 references to 1006, the Code of Federal Regulations that is specific to Regulation F.

The manual is broken down into seven modules:

  • Entity Business Model
  • Communications in Connection with Debt Collection
  • Information Sharing, Privacy, and Interactions with Consumer Reporting Agencies
  • Validation Notice, Consumer FDCPA Disputes and Complaints, and Ceasing Communication
  • Payment Processing and Account Maintenance
  • Equal Credit Opportunity Act
  • Litigation Practices, Administrative Wage Garnishment and Repossession, and Time-Barred Debt

There are references in the updated module to the Limited-Content Message, collecting using email and text messaging, and other components of Regulation F that now need to be overseen.

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