Collector – July 2019 - 53

GOVERNMENTAFFAIRS

However, under the sandbox policy,
entities in the debt collection industry
would be limited in the types of other
relief that could be afforded to them.
* The sandbox policy only provides
approval relief under three statutory
safe harbor provisions: the Truthin-Lending Act, the Equal Credit
Opportunity Act and the Electronic
Funds Transfer Act. Those statutory
safe harbors allow an applicant full
immunity from private rights of action.
For members of the debt collection
industry, such relief is not afforded
under TILA and ECOA, although there
may be some very remote opportunities
for relief under EFTA. The Fair Debt
Collection Practices Act has not yet
been addressed.
* Under the sandbox policy, the CFPB
notes only three statutes: The ECOA,
the Home Owners Equity Protection
Act and the Federal Deposit Insurance
Act, which provide relief by exemptionby-order from not only supervision
and enforcement, but civil lawsuits as
well. The sandbox policy is silent as to
whether the CFPB will consider other
consumer financial statutes. In order to
encourage the debt collection industry
to participate in the product sandbox,
the CFPB must provide exemptions-byorder under the FDCPA.
* Unlike the NAL policy, the sandbox
policy mandates that all denials will be
published. ACA outlined reservations
about encouraging its members to
apply to the product sandbox if their

COLLECTOR 07.19

company information along with the
reasons for denial is published.
* ACA also noted that collaboration
with the states is perhaps the
most critical factor to ensure that
companies are not exposed to
frivolous litigation or enforcement
actions at the state level when
participating.
ACA is awaiting more information
about how NAL and the product sandbox
will work for the debt collection industry.

Save
Date!

In the meantime, we encourage ACA
members to consider how they might want
to use this opportunity to innovate. We
continue to seek clarity from the CFPB
and are more than willing to assist ACA
members who are interested in having
further discussions with the bureau about
these programs.
Leah Dempsey is ACA International's vice
president and senior counsel of federal
advocacy.

THE

"ACA is awaiting more
information about how
NAL and the product
sandbox will work for the
debt collection industry."

ACA INTERNATIONAL

FALL FORUM & EXPO

2019

CHICAGO

NOV 6-8
THE DRAKE

53



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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