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NAFCU details impact of debt collection rule on CUs
NAFCU Monday sent members a Final Regulation summary outlining what credit unions need to know about the CFPB's final rule to amend Regulation F, which implements the Fair Debt Collection Practices Act (FDCPA). Finalized earlier this month, the rule heeded several concerns NAFCU had flagged for the bureau in its comments on the proposal.
Read the final rule here. NAFCU previously urged the bureau to exempt credit unions from any rulemaking related to debt collection, as they are not the bad actors the rules are meant to address.
Through the alert, NAFCU highlights that the rule:
- applies only to third-party debt collectors, as defined by the FDCPA;
- clarifies the time, place, and manner restrictions on how a debt collector may communicate with a consumer; and
- finalizes limited content messages, but only for voicemails. Debt collectors may communicate through email, text message, and social media so long as the consumer has been given an opt-out.
Additionally, the alert provides a general overview of the rule and how it impacts credit unions, including a section by section analysis. The rule will become effective one year after publication in the Federal Register.
The CFPB has also indicated that it plans to issue a separate disclosure rule later this year, in addition to a disclosure for time-barred debt. In its comments on the supplemental notice of proposed rulemaking on time-barred debt, NAFCU urged the bureau to exclude credit unions from the rule and highlighted other concerns.