DBA Submits Response to CFPB’s Debt Collection ANPR
On Thursday, February 27, 2014, DBA International submitted a detailed response to the Consumer Financial Protection Bureau’s (CFPB) Advanced Notice of Proposed Rulemaking (ANPR) regarding consumer debt collection practices, dated November 6, 2013. 78 Fed. Reg. at 67868. Click here to view a copy of DBA’s response.
We appreciate the thoughtful input and commitment of DBA members in the drafting of this response. Throughout our ANPR response, we emphasize five overarching principles:
- Consumer access to credit is a privilege – not a right. When this privilege is exercised appropriately, everyone benefits – consumer borrowers, lenders and, ultimately, the nation’s economy.
- Ethical debt buying and selling provides important benefits – to consumer borrowers who are assisted in meeting their repayment responsibilities; to lenders who receive a return on their investment; and to the consumer credit economy which debt buying helps to catalyze.
- The law should protect and promote ethical debt collection, which safeguards the rights of consumers and provides rules of the road for collectors.
- The law should not be misused to enable borrowers to turn legitimate loans into de facto gifts. In the long run, this will reduce the availability of credit for all consumers and make credit more expensive.
- The law should be as clear as possible – effective rules; effective remedies; and appropriate safe harbors for good faith efforts to comply with the law.
The DBA Certification Standards are often referenced throughout the response demonstrating how these robust standards promote ethical, uniform and consumer protective industry conduct.
February 28, 2014