The Consumer Financial Protection Bureau (CFPB) should ensure its debt collection rulemakings do not extend unwarranted regulatory requirements to first-party debt collectors, CUNA wrote Tuesday in response to a CFPB proposal. The proposal would amend Regulation F to require debt collectors to make certain disclosures when collecting time-barred debts (debts for which the applicable statute of limitations has expired).
“We respectfully recommend the Bureau continue to rely solely on its Fair Debt Collection Practices Act (FDCPA) authority when promulgating rules governing the practice of debt collection,” the letter reads. “The FDCPA provides the Bureau with ample ability to achieve its desired limitations on third-party collections without exposing credit unions that collect their own debts to expanded regulatory compliance and litigation burden.”
The letter also calls for the CFPB to: