The comments were submitted in response to the National Conference of Commissioners on Uniform State Laws’ recent request for comments on the proposed revisions to the Uniform Debt-Management Services Act (UDMSA).
NCLC remains deeply concerned that the UDMSA does not adequately protect consumers from abusive debt settlement and debt management practices. We previously explained our concerns in our March 2006 comments, which are attached to this letter as Appendix I. More recently, the Federal Trade Commission and the Government Accountability Office have investigated debt-settlement practices and documented the continued existence of misconduct and abuse by debt-settlement providers. While some of NCCUSL’s proposed changes to the UDMSA will improve protections for consumers, the changes do not go far enough and, in some regards, represent a step backwards.