Thursday, April 8, 2021

FYI: CFPB Seeks to Delay Effective Date of FDCPA Final Rules (Regulation F)

On April 7, 2021, the Consumer Financial Protection Bureau issued a Proposed Rule that would postpone the effective date of the Debt Collection Final Rules, Part 1 and Part 2, by 60 days, from Nov. 30, 2021, to Jan. 29, 2022.


The CFPB cites the "disruption caused by the global COVID-19 pandemic" as the impetus for the Proposed Rule, which if finalized would "afford stakeholders additional time to review and, if applicable, to implement the Debt Collection Final Rules."  The CFPB notes that because of the short delay proposed, any reduction in benefits provided to consumers should be minimal.


The CPFB advises that while "debt collectors could choose to comply with the rules' requirements and prohibitions before the effective date," the safe harbors would not yet apply. 


The CFPB specifically requests comment on:


  • Whether the effective date should be extended;
  • Whether 60 days is an appropriate timeline;
  • Whether the original effective date should be kept for all or some of the safe harbors considering, for example, the costs and benefits they may provide to debt collectors;
  • Whether the extension may reduce access to consumer financial products and services; and
  • Any additional information relating to "potential benefits, costs, and impacts of this proposed rule."


Public comments must be submitted on or before the 30th day after the Proposed Rule is published in the Federal Register.





Ralph T. Wutscher
Maurice Wutscher LLP
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