Collector – July 2019 - 20

QUESTIONS ABOUT THE PROPOSED RULE?
We have answers.
Q: Who does it apply to?
A: Debt collection agencies, debt buyers, debt collection

law firms, loan servicers-anyone who falls under the
purview of the FDCPA. This definitely includes third-party
debt collectors but could also include some first-party
debt collectors.

Q: Does the proposed rule supersede
the Telephone Consumer Protection Act?
A: Unfortunately, right now we don't know. It's a question

ACA has raised and will continue to seek clarity on from
both the FCC and CFPB, because a lot of the information
in the proposed rule does overlap with the TCPA.

Q: When do I have to start complying with it?
Should I start making changes to my
business practices today?
A: The comment period on the proposed rule is still open.

business, but also so you aren't caught off guard when the
rule does become official.
Some companies may decide to start implementing
parts of the proposed rule into their compliance
management system now. For example, your compliance
team may decide to begin using the form validation
notice provided because they feel it's compliant within
the existing state of the law, or maybe the proposed rule
prompts you to start encouraging your clients to obtain
E-SIGN consent in consumer contracts. Your compliance
team can determine which guidance your company might
consider incorporating now, but don't hang your hat on
every tiny detail as we just don't know what will change
down the road.

Q: What if I have a concern about the proposed rule?
A: Submit your comments directly to the CFPB through

its comment portal at www.regulations.gov or via email:
2019-NPRM-DebtCollection@cfpb.gov. Include "Docket
When it closes Aug. 19, it will take at least several more
No. CFPB-2019-0022 or RIN 3170-AA41" in the subject
months before we have a full-fledged law. It might even
line of the email.
take the CFPB more than a year to review all the feedback
it receives. And after that, we may see
varying compliance deadlines and dates
for implementation. Based on what we're
seeing, ACA estimates the rule may take
effect some time after Jan. 1, 2021.
However, your compliance, operations
and executive teams should start reviewing
the proposed rule now. How would you
implement the suggested changes, how
much would they cost and how fast could
you get them in place? Start planning-not
only so you can provide feedback to the
ACA CEO Mark Neeb and Board President Jack Brown are among staff and members who attended the
CFPB's town hall meeting in Philadelphia May 8.
CFPB on the rule's potential effect on your

FEB 2014

ACA submits
comments to the
CFPB's debt
collection ANPR.

20

MAR 2014

CFPB announces plans
to survey consumers
about their experiences
with debt collectors as
part of its rulemaking.

MAY 2014

ACA submits comments
urging the CFPB to
discontinue pursuit of
its proposed consumer
survey, noting that the
design is flawed and the
content suffers from a
negative bias.

NOV 2014

CFPB pushes its prerule activities related
to debt collection to
April 2015.

JAN 2015

The CFPB mails letters
to randomly selected
consumers, inviting
them to participate in
the survey on credit
and debt.

ACAINTERNATIONAL.ORG


http://www.regulations.gov http://www.ACAINTERNATIONAL.ORG

Collector – July 2019

Table of Contents for the Digital Edition of Collector – July 2019

Upfront
Industry News
Best Practices
FYI
Collection Tips
What you need to know about the CFPB’s proposed new rule for the debt collection industry
“I don’t know about you, but I’ve literally never received a telegram and wouldn’t even know how to send one.”
Celebrating 80 Years of Helping Members Succeed
How Does ACA Help Members Succeed?
A History of Advocacy
8 Decades of ACA’s Annual Convention
Calendar
Honor Roll
Education Spotlight
Tell It Like It Is: Washington Hears From ACA Members
Collectors Challenge 2019: Getting Creative for a Good Cause
Balance it Out
Balance Billing Challenges Continue
It’s All About You: Helping Members Succeed
Sandbox Rules
What is a Product Sandbox?
in 11th Circuit Case Examining What Constitutes an ATDS
ACA SearchPoint
Ad Index
Membership
Last Word
Collector – July 2019 - Cover1
Collector – July 2019 - Cover2
Collector – July 2019 - 1
Collector – July 2019 - 2
Collector – July 2019 - 3
Collector – July 2019 - Upfront
Collector – July 2019 - 5
Collector – July 2019 - Industry News
Collector – July 2019 - 7
Collector – July 2019 - 8
Collector – July 2019 - 9
Collector – July 2019 - Best Practices
Collector – July 2019 - 11
Collector – July 2019 - FYI
Collector – July 2019 - 13
Collector – July 2019 - Collection Tips
Collector – July 2019 - 15
Collector – July 2019 - What you need to know about the CFPB’s proposed new rule for the debt collection industry
Collector – July 2019 - 17
Collector – July 2019 - “I don’t know about you, but I’ve literally never received a telegram and wouldn’t even know how to send one.”
Collector – July 2019 - 19
Collector – July 2019 - 20
Collector – July 2019 - 21
Collector – July 2019 - 22
Collector – July 2019 - 23
Collector – July 2019 - Celebrating 80 Years of Helping Members Succeed
Collector – July 2019 - 25
Collector – July 2019 - How Does ACA Help Members Succeed?
Collector – July 2019 - 27
Collector – July 2019 - 28
Collector – July 2019 - 29
Collector – July 2019 - A History of Advocacy
Collector – July 2019 - 31
Collector – July 2019 - 8 Decades of ACA’s Annual Convention
Collector – July 2019 - 33
Collector – July 2019 - 34
Collector – July 2019 - 35
Collector – July 2019 - Calendar
Collector – July 2019 - Honor Roll
Collector – July 2019 - Education Spotlight
Collector – July 2019 - 39
Collector – July 2019 - Tell It Like It Is: Washington Hears From ACA Members
Collector – July 2019 - 41
Collector – July 2019 - Collectors Challenge 2019: Getting Creative for a Good Cause
Collector – July 2019 - 43
Collector – July 2019 - Balance Billing Challenges Continue
Collector – July 2019 - 45
Collector – July 2019 - 46
Collector – July 2019 - 47
Collector – July 2019 - It’s All About You: Helping Members Succeed
Collector – July 2019 - 49
Collector – July 2019 - 50
Collector – July 2019 - 51
Collector – July 2019 - What is a Product Sandbox?
Collector – July 2019 - 53
Collector – July 2019 - in 11th Circuit Case Examining What Constitutes an ATDS
Collector – July 2019 - 55
Collector – July 2019 - ACA SearchPoint
Collector – July 2019 - Ad Index
Collector – July 2019 - Membership
Collector – July 2019 - 59
Collector – July 2019 - Last Word
Collector – July 2019 - Cover3
Collector – July 2019 - Cover4
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