Collector – November 2019 - 19

for mishandling consumer credit reporting
disputes and failing to send validation notices.
According to the CFPB, Syndicated Office
Systems failed to respond to more than
13,000 consumer credit report disputes
within the 30-day timeframe required by law.
On average, the company took more than 90
days to respond to consumers' disputes and,
in some cases, took over a year. The company
also allegedly failed to send debt validation
notices to more than 10,000 consumers.
The CFPB ordered Syndicated Office
Systems to pay more than $5.4 million in
relief, plus a $500,000 penalty.
As part of its proposed debt collection
rulemaking, the CFPB addresses credit
reporting practices, specifying that agencies
must communicate with consumers about
the debt before credit reporting it.
The proposed rule does not currently
specify that collectors need to explicitly
tell consumers they are planning to credit
report, only that they need to communicate
about the debt.
Specific requirements may change before
the bureau adopts finalized rules, so taking
action based on the proposed rules would
be premature. However, businesses may
want to begin considering what policies they
will implement if the proposed rules are
approved as they currently stand.

THE FUTURE
Medical debt and the way it is credit
reported will continue to be hot topics.

The CFPB and state attorneys general are
sensitive to the manner in which medical
debt arises and seek to ensure consumers
are treated fairly.
With the amount of medical debt showing
no signs of significantly declining, the courts
will surely continue to consider cases affecting
medical debt collection practices as well.
Agencies collecting medical debt should
continue to fine-tune their practices as such
developments warrant.
In light of the trends discussed here,
agencies can:
* Review their credit reporting
procedures to ensure they report
accounts in the same manner that
clients provide them.
* Establish policies for identifying
and handling disputes from credit
repair organizations.
* Consider how they will adapt their
policies if the CFPB adopts its
proposed rules as they have
been published.
Refining and following compliance policies
and procedures are often the best steps
to respond to court rulings and regulator
action affecting collection practices. These
developments surrounding credit reporting
medical debt are no exception, and provide
a worthwhile opportunity to adapt your
compliance efforts.
Tim Dressen is a communications consultant
and former editor of Collector magazine.

LAWS GOVERNING MEDICAL DEBT
COLLECTION & CREDIT REPORTING
* Fair Debt Collection Practices Act
* Fair Credit Reporting Act
* National Consumer Assistance Plan
* State Laws
* Health Insurance Portability and Accountability Act
* Internal Revenue Code Section 501(r)
* Telephone Consumer Protection Act

COLLECTOR 11.19

1

The Seventh Circuit Court
said a collector does not
misrepresent the character
of a debt by reporting unpaid
medical bills owed to a single
provider separately. Report
each separate charge as it's
sent to you by the client.

2

The CFPB's proposed
debt collection rule
specifies that agencies
must communicate with
consumers about their debt
before credit reporting it.

3

If you are processing
disputes from a credit
repair organization, talk
to your attorney and put
together a policy that
outlines what you do with
those disputes.
19



Collector – November 2019

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

Upfront
Industry News
Best Practices
FYI
Collection Tips
Do Your Policies Measure Up?
The Life-Changing Magic of Tidying Up Your Call Evaluations
The (Slow) Race to Clarify the TCPA
Honor Roll
Calendar
Education Spotlight
ACA’s LevelUp Leadership Experience
Lead the Next Generation Through Mentorship
Texas Tackles the TCPA
Never Give Up
A Resource Every Member Needs
Rising to the Top
ACA SearchPoint
Ad Index
Membership
Last Word
Collector – November 2019 - Cover1
Collector – November 2019 - Cover2
Collector – November 2019 - 1
Collector – November 2019 - 2
Collector – November 2019 - 3
Collector – November 2019 - Upfront
Collector – November 2019 - 5
Collector – November 2019 - Industry News
Collector – November 2019 - 7
Collector – November 2019 - 8
Collector – November 2019 - 9
Collector – November 2019 - Best Practices
Collector – November 2019 - 11
Collector – November 2019 - FYI
Collector – November 2019 - 13
Collector – November 2019 - Collection Tips
Collector – November 2019 - 15
Collector – November 2019 - Do Your Policies Measure Up?
Collector – November 2019 - 17
Collector – November 2019 - 18
Collector – November 2019 - 19
Collector – November 2019 - The Life-Changing Magic of Tidying Up Your Call Evaluations
Collector – November 2019 - 21
Collector – November 2019 - 22
Collector – November 2019 - 23
Collector – November 2019 - The (Slow) Race to Clarify the TCPA
Collector – November 2019 - 25
Collector – November 2019 - 26
Collector – November 2019 - 27
Collector – November 2019 - 28
Collector – November 2019 - 29
Collector – November 2019 - 30
Collector – November 2019 - Honor Roll
Collector – November 2019 - Calendar
Collector – November 2019 - 33
Collector – November 2019 - Education Spotlight
Collector – November 2019 - 35
Collector – November 2019 - ACA’s LevelUp Leadership Experience
Collector – November 2019 - 37
Collector – November 2019 - Lead the Next Generation Through Mentorship
Collector – November 2019 - 39
Collector – November 2019 - Texas Tackles the TCPA
Collector – November 2019 - 41
Collector – November 2019 - Never Give Up
Collector – November 2019 - 43
Collector – November 2019 - A Resource Every Member Needs
Collector – November 2019 - 45
Collector – November 2019 - Rising to the Top
Collector – November 2019 - 47
Collector – November 2019 - ACA SearchPoint
Collector – November 2019 - Ad Index
Collector – November 2019 - Membership
Collector – November 2019 - 51
Collector – November 2019 - Last Word
Collector – November 2019 - Cover3
Collector – November 2019 - Cover4
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