The Consumer Financial Protection Bureau (CFPB) announced on July 30, 2021 that it will be withdrawing its earlier proposal to extend the Regulation F effective date by 60 days.
Thus, the original effective date of Nov. 30, 2021, will remain.
A copy of the announcement is available at: Link to Announcement
The proposal to extend the date, discussed here, was intended to address the "disruption caused by the global COVID-19 pandemic" and "afford stakeholders additional time to review and, if applicable, to implement the Debt Collection Final Rules." According to the CFPB, "[t]he public comments generally did not support an extension."
Although the comments from industry generally indicated readiness by the original effective date, a number of consumer advocates pushed for an extension.
Consumer advocate commenters generally supported extending the effective date, but they did not focus on whether additional time is needed to implement the rules. The alternative basis for an extension that many commenters urged, a reconsideration of the rules, was beyond the scope of the NPRM and could raise concerns under the Administrative Procedure Act.
However, the CFPB noted that "[n]othing in this decision precludes the CFPB from reconsidering the debt collection rules at a later date."
Ralph T. Wutscher
Maurice Wutscher LLP
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