Update: CUNA's summary of the rule is available here.
The Consumer Financial Protection Bureau (CFPB) released its final rule on debt collection Friday. The rule prescribes certain disclosures and conduct limitations for covered debt collectors, as that term is defined under the Fair Debt Collection Practices Act (FCDPA). The FDCPA and the Bureau’s final rule will regulate the activities of third-party debt collectors and not entities collecting their own debts, commonly referred to as “first-party debt collectors.”
“Credit unions treat members with respect during the debt collection process,” said CUNA President/CEO Jim Nussle. “While this rule is designed to implement the FDCPA, we remain concerned about the potential impacts the rule could have on the credit ecosystem. Because they are the owners of the credit union, credit union members have an interest in debt collection practices that are effective, fair and efficient. We will continue to evaluate the rule to determine its full impact on credit unions and their partners."
The Bureau is expected to finalize a supplemental debt collection rule focused on time-barred debt disclosures in the near future.
CUNA continues to oppose any legislative or regulatory efforts to expand the scope of the FCDPA to credit unions that collect their own debts.