Call balls and strike on debt collection rule

Show Notes:

Georgetown professor Adam Levitin stops by Clark Hill’s Credit Eco to Go to give his unbiased take on the CFPB’s final debt collection rule.

Overall, Adam supports having clear rules of conduct whether or not you agree with the rule itself. He agrees that it is very important to have a rule that provides guidance for debt collectors to navigate the e-ecosystem and was happy to see that a model validation was finalized but thinks it will be changed over time. Adam worries about frequency limits on attempts to communicate over the phone and worries that repeated unwanted calls will turn into harassment.

Finally, Adam was very surprised that the CFPB had not moved forward with a final prescribed debt rule, but suspects that the issue could still be resolved later, perhaps through UDAAP regulation. The conversation about debt collection and the debt collection rule can head into extra innings.


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