Collector – July 2019 - 52

GOVERNMENTAFFAIRS

Sandbox Rules
ACA supports the CFPB's efforts to encourage financial services innovation.
By Leah Dempsey

E

arlier this year, the Consumer
Financial Protection Bureau
sought comments on a new policy
surrounding no-action letters (NAL) and a
"product sandbox," signaling a more serious
commitment to innovation than what we
have seen in the past.
The bureau proposed overhauling parts
of the NAL while also providing certain
safe harbors and regulatory and statutory
relief for those seeking to participate.
This initiative, which runs parallel
to rulemaking for the debt collection
industry, could offer an opportunity
for the industry to try new disclosures,
technologies, or other ways of innovating.
However, several questions remain about
how this initiative will pertain to the
accounts receivable management industry,
which arguably need to be answered before
it can be a useful tool for ACA members.

Notably, the CFPB's 2016 policy provided
only one NAL. As the CFPB noted in its
request for comment when considering new
policies, "This strongly suggests that both
the process required to obtain a No-Action
Letter and the relief available under the
2016 policy have not provided firms with
sufficient incentives to seek No-Action
Letters from bureau staff."
The bureau seeks comments on changes
to the 2016 policy that would address these
issues and bring certain aspects of the policy
into alignment with NAL programs offered
by other federal regulators.
ACA filed comments and has held
meetings with the CFPB in support of its
fresh look at the initiative. In our comments,
we stated that we believe the accounts
receivable management industry would
benefit significantly from the NAL and
product sandbox initiatives. We argued that

the industry is ripe for testing new ideas
and incorporating technologies into current
processes in order to achieve industrywide standards that consumers want, and
provide better protections for consumers by
establishing clear-cut regulatory expectations.
The bureau indicated that some of its
overarching goals for the NAL and sandbox
policy are to streamline the application
process, expand the types of statutory and/
or regulatory relief available and potentially
coordinate with existing or future programs
offered by other regulators designed to
facilitate innovation.
However, these are aspects of the proposal
ACA urged clarity on:
* ACA supports the willingness of the
CFPB to expand the product sandbox
protections to include no-action relief
and waiver of unfair, deceptive, or
abusive acts or practices (UDAAP).

What is a
Product
Sandbox?
When the CFPB talks
about its "product sandbox,"
it's referring to a supervised
environment for fintech
companies to test new
products on real customers
without incurring regulatory
penalties.

52

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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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