The National Consumer Law Center (on behalf of its low income clients), Americans for Financial Reform Education Fund, Consumer Federation of America, National Association of Consumer Advocates, U.S. PIRG, and Woodstock Institute submit these comments on the Consumer Financial Protection Bureau‘s (CFPB or Bureau) proposed debt collection rule.
We are terribly disappointed with the proposed regulations, which do far more to protect abusive collectors than consumers. The primary goal appears to be to make it easier for collectors to collect debts, to give them more vehicles to pressure and harass people who simply cannot afford to pay, and to protect collectors from responsibility for violating the law and abusing consumers. While there are instances in which the regulations clarify and improve protections, the overall impact of these regulations, should they be promulgated, will be to hurt consumers, not help them.
The CFPB has the power to do tremendous good with regulations on debt collection. But this proposal will not meet that goal. We urge the CFPB to go back to the drawing board, and reissue proposals that will enhance the protections for consumers from abusive, harassing, and unfair debt collections.