NARCA Small Business Review Panel Survey |
Introduction
The CFPB will distribute its regulatory proposals to the small business representatives for review, discussion and comment. It is unknown what proposals the CFPB may ask the small business representatives to review, but the Advance Notice of Proposed Rulemaking (right click to view page) included the following relevant sections:
· Part II - Transfer of information and access to information upon sale or placement of debts.
· Part III - Validation notices, disputes, investigations, and verification of disputes.
· Part IV - Collector communications seeking location information about consumers, interacting with consumers themselves, disclosing debts to third parties, and newer technologies and issues concerning sections 804 and 805 of the FDCPA.
· Part V - Unfair, deceptive, and abusive acts and practices, including issues concerning sections 806, 807, and 808 of the FDCPA.
· Part VI - Collection of debts that are beyond the statute of limitations.
· Part VII - Debt collection litigation, most of which occurs in State courts.
· Part II - Transfer of information and access to information upon sale or placement of debts.
· Part III - Validation notices, disputes, investigations, and verification of disputes.
· Part IV - Collector communications seeking location information about consumers, interacting with consumers themselves, disclosing debts to third parties, and newer technologies and issues concerning sections 804 and 805 of the FDCPA.
· Part V - Unfair, deceptive, and abusive acts and practices, including issues concerning sections 806, 807, and 808 of the FDCPA.
· Part VI - Collection of debts that are beyond the statute of limitations.
· Part VII - Debt collection litigation, most of which occurs in State courts.