ARTICLE
3 September 2021

CFPB Debt Collection Regulations Will Go Into Effect On November 30

CW
Cadwalader, Wickersham & Taft LLP

Contributor

Cadwalader, established in 1792, serves a diverse client base, including many of the world's leading financial institutions, funds and corporations. With offices in the United States and Europe, Cadwalader offers legal representation in antitrust, banking, corporate finance, corporate governance, executive compensation, financial restructuring, intellectual property, litigation, mergers and acquisitions, private equity, private wealth, real estate, regulation, securitization, structured finance, tax and white collar defense.
The effective date of two final rules remains November 30, 2021.
United States Finance and Banking
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The CFPB published in the Federal Register the withdrawal of an April 2021 rule proposal that would have delayed the effective date of two final rules on debt collection communications under the Fair Debt Collection Practices Act. The effective date of two final rules remains November 30, 2021.

The first rule, adopted in October 2020, clarifies prohibitions on misleading representations, harassment and abuse, and unfair debt collection practices. The second rule, adopted in December 2020, clarifies disclosure obligations for debt collectors at the beginning of collection communications, as well as prohibited predatory activities.

As previously covered, the CFPB stated the proposed delay was intended to allow additional time to implement the rules in light of the COVID-19 pandemic, but that industry commenters generally stated they would be prepared to comply by November 30, 2021.

Primary Sources

  1. Federal Register: Debt Collection Practices (Regulation F); Withdrawal of Proposal To Delay Effective Date

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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