Collector - September 2017 - 33

at ACA, she served as an associate attorney
at Patton Boggs LLP in Washington, D.C.,
where she worked on issues in the financial
services and communication technology
fields, with a particular focus on matters
before the Federal Communications
Commission, including TCPA Act issues.

Q
A

What's a Typical
Workday Like for You?
Wolvin: In my role, I cover the activity
of federal regulators that impact the
credit and collection industry. This primarily
includes the Consumer Financial Protection
Bureau, Federal Trade Commission and
Federal Communications Commission's
handling of the TCPA.
I work closely with ACA's government
affairs, compliance and legal teams as well as
ACA's Federal Affairs Committee.
My days are a combination of being
proactive and reactive as I keep up with
everything going in and coming out of
federal agencies that affect our industry
and assess what each might mean to our
members. I engage with these agencies to
ensure they understand the important role
of the credit and collection industry and to
advocate for balanced and well-reasoned
regulations and policies.
I also work hard to ensure that ACA
members are informed in a timely way about
regulatory developments, and I often solicit
feedback from our members to help inform
ACA's advocacy efforts.

Q
A

How Does Your Role
Impact ACA Members?
Wolvin: The regulatory environment
is hugely important for ACA members.
The CFPB and TCPA impact what our
members do every single day. Given this,
it's paramount that ACA has a strong and
consistent voice with federal regulators so that
they understand the value of debt collection
and the real-world impact of the rules and
policies that come out of Washington, D.C.

Q
A

What's the Most Rewarding
Part of Your Job?
Wolvin: I fundamentally believe in
the vital role that debt collection plays

COLLECTOR 09.17

in our credit-based economy. As a lawyer
with over 10 years of policy experience, I
enjoy taking this belief and transforming
it into the basis of a comprehensive
strategy to change the misleading narrative
surrounding debt collection, to promote
the legitimate debt collection industry, and
to work for fair and balanced rules that
protect all consumers, not just those who
have outstanding debt.

Q
A

What's the Most Challenging
Part of Your Job?
Wolvin: There are a lot of unjustified
and misleading perceptions of the
debt collection industry, so when you are
developing a government affairs strategy the
starting point is always a little challenging to
try to get your audience to deconstruct any
preconceived notions they might have about
debt collection.
You have to make sure they have an
accurate understanding of the essential
role that this industry plays in helping
other businesses thrive and keeping
the cost of credit down for consumers,
as well as the operational realities
faced by legitimate debt collectors, the
overwhelming majority of which are small
businesses, in providing this vital service
to the economy.

Q
A

Can You Tell Me About a
Professional Highlight From
Your Time at ACA?
Wolvin: Last summer, when the
CFPB released its third-party debt
collection outline of proposed rules
under consideration, we had several ACA
members who were selected to be small
entity representatives in the SBREFA panel
process. ACA worked closely with them
through a very intense process in trying
to not only understand the proposals, but
to also understand the potential impact
those proposals would have on third-party
debt collection small businesses, and then
to be able to develop the most effective
way to describe those challenges.
It was a really intense process requiring
a tremendous amount of work in a
very constrained timeframe, and the

small entity representatives, both in the
panel meeting and in written comments
afterwards, did a truly impressive job of
making sure all the points that were the
most difficult and challenging about the
outline were addressed in a data-driven
way with the CFPB.
One of the focal points of contention
was that first-party creditors who are
inextricably linked to third-party debt
collectors' ability to substantiate a debt
were not included in the SBREFA panel
process in August 2016. Although
substantiation comprised a large part of
the CFPB's outline of proposals, without
knowing the information possessed by
first parties or the obligations the CFPB
intends to impose on first parties, there
was really no way for third-party debt
collectors to provide meaningful input
on the CFPB's substantiation proposals
without first parties being included in the
process.
Ultimately, after ACA and the small
entity representatives advocated for
almost a year about that failure, [CFPB
Director Richard] Cordray announced
in June that the CFPB is going to change
direction and remove the substantiation
proposals from the third-party rules
and wait to address them jointly during
a future first-party debt collection
rulemaking.
As a result, first and third parties
will now have the opportunity to
provide feedback simultaneously on
the substantiation proposals, which,
as the CFPB has acknowledged, are
"intertwined." This was an important
procedural victory for the debt collection
rulemaking and a highlight in our work
advocating for fair and well-reasoned debt
collection rules with the CFPB.

Did You Know?

19

Number of small entity
representatives involved in
the SBREFA panel process,
the majority of whom are
also ACA members.

33



Table of Contents for the Digital Edition of Collector - September 2017

Collector - September 2017 - Cover1
Collector - September 2017 - Cover2
Collector - September 2017 - 1
Collector - September 2017 - 2
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