In the most recent edition of its Supervisory Highlights, the Consumer Financial Protection Bureau (CFPB) makes only brief mention of debt collection. In fact, it was so brief that it can be summed up in two simple points:

  1. A debt collector didn't disclose that it was a debt collector in subsequent communications; and
  2. A debt collector didn't send the 1692g validation notice to consumers within five days of the initial communication.

The debt collector(s) in these situations amended their policies, and that was that. 


insideARM Perspective

From such a brief edition of the highlights comes an interesting observation. A few short months ago, the CFPB made a big deal about credit reporting. Credit reporting was front-and-center of the joint workshop put on by the CFPB and the FTC in December. It was also a major issue discussed in the CFPB's Summer 2019 Supervisory Highlights, released in September. Even the CFPB's semi-annual report, released in October, contained several items related to credit reporting. Yet, in this most recent Highlights edition, there is no mention of it other than as a reference in a section discussing alternative data. What a strange turn.

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