Allied Progress Analysis Finds At Least 1-in-7 CFPB Debt Rule Public Comments Came From Debt Industry Personnel

But Do Any Actual CONSUMERS Support The CFPB’s Plan to Flood Families With Unlimited, Unsolicited Texts and Emails From Debt Collectors?

WASHINGTON, D.C. – With the public comment period officially ended for the CFPB’s debt collection proposal, consumer watchdog group Allied Progress released an analysis finding that at least 1,221 comments filed in support of the rule came openly from the debt collection industry – amounting to 1 out of every 7 of the 9,386 total comments submitted at the time of the group’s review on September 18th. *See details below. Meanwhile, comments in support of the rule from people portraying themselves as regular consumers appear to be few and far between – a result that reflects the polling finding overwhelming, bipartisan opposition to the CFPB’s plan to let debt collectors send unlimited, unsolicited texts and emails to consumers, oftentimes over “zombie” debts too old to be legally pursued or that don’t even belong to the person.

“When virtually the only people excited about the CFPB’s debt spam plan are those enriched by it, Director Kraninger should admit her proposal has nothing to do with protecting consumers – and everything to do with helping an industry that funds GOP campaigns,” said Jeremy Funk, spokesman for Allied Progress. “With so little support from consumers, Kraninger has even less justification for giving the debt industry almost everything they asked for. She still has an opportunity to put consumers first in the final rule. If not, consumers better get used to never-ending texts and emails at all hours from strangers asking for money.” 

BACKGROUND: The CFPB’s debt collection proposal isn’t just wildly unpopular, it’s likely illegal after a Federal appeals court recently ruled debt collection agencies were prohibited from asking consumers to click on hyperlinks to obtain legally-required notices about outstanding debt. The proposal seeks to permit exactly that. The Trump spam plan rewards the debt collection industry despite racking up among the highest number of consumer abuse complaints and millions of dollars in fines and legal penalties for misconduct. Allied Progress recently released an analysisshowing the debt collection industry trade groups have spent over $2.1 million on federal lobbying since Trump took office, and debt collectors have donated over $343,000 to Republican political campaigns since 2016. That followed Allied Progress’ reportspotlighting the history of consumer abuse from some of the debt collection industry’s biggest players.

WHAT YOU NEED TO KNOW: 

Comments From Industry Employees Flood CFPB

Debt Collection Industry Insiders Have Submitted At Least 1,221 Comments In Support Of The CFPB’s Proposed Debt Collection Rule—Constituting At Least 1 Out Of Every 7 Comments On The Rule.

As Of September 18, 2019, 9,386 Total Comments Have Been Submitted On The CFPB’s Proposed Rule On Debt Collection Practices (Regulation F).

As Of September 18, 2019, 9,386 Public Comments Have Been Submitted On The CFPB’s Proposed Rule On Debt Collection Practices (Regulation F).[Docket for CFPB-2019-0022, Regulations.gov. accessed 09/18/19]

At Least 108 Comments State, Verbatim, “I Appreciate That The CFPB Has Created A Model Validation Notice That Would Provide Important Disclosures And Information To Consumers And Give OurIndustry A Safe Harbor From Litigation” [Emphasis Added].

At Least 108 Submitted Comments On The CFPB’s Proposed Rule On Debt Collection Practices (Regulation F) Contain The Exact Phrase: “I Appreciate That The CFPB Has Created A Model Validation Notice That Would Provide Important Disclosures And Information To Consumers And Give Our Industry A Safe Harbor From Litigation.”[Docket Browser Search for CFPB-2019-0022, Regulations.gov, accessed 09/18/19]

At Least 54 Of These Comments Say, “Thank You For Your Efforts To Provide More Clarity And Transparency For Collectors And OurConsumers.” [Docket Browser Search for CFPB-2019-0022, Regulations.gov, accessed 09/18/19]

At Least 657 Comments State, Verbatim: “The Seven Call-Cap Per Week Will Make It Harder To Connect With OurConsumers” [Emphasis Added]

At Least 657 Submitted Comments On The CFPB’s Proposed Rule On Debt Collection Practices (Regulation F) Contain The Exact Phrase: “The Seven Call-Cap Per Week Will Make It Harder To Connect With Our Consumers.” [Docket Browser Search for CFPB-2019-0022, Regulations.gov, accessed 09/18/19]

  • At Least 154 Of These Comments Claim, “Updating Antiquated Laws To Reflect How People Communicate Today Will Help Both Our Industry And Our Consumers.” [Docket Browser Search for CFPB-2019-0022, Regulations.gov, accessed 09/18/19]

At Least 456 Comments State, Verbatim: “I Urge The CFPB To […] Provide Much-Needed Safe Harbors”—And Nearly All Of Them Praise The Industry And Direct The CFPB Toward A Comment From The Industry’s Biggest Trade Group.

At Least 456 Submitted Comments On The CFPB’s Proposed Rule On Debt Collection Practices (Regulation F) Contain The Exact Phrase: “I Urge The CFPB To Move Forward With The Important Aspects Of The Rule That Embrace Modern Communication Methods And Provide Much-Needed Safe Harbors.”[Docket Browser Search for CFPB-2019-0022, Regulations.gov, accessed 09/18/19]

At Least 451 Of These Comments Claim, “The Accounts Receivable Management Industry Annually Recovers Billions In Unpaid Debt That Is Returned To And Reinvested By Businesses.”[Docket Browser Search for CFPB-2019-0022, Regulations.gov, accessed 09/18/19]

At Least 452 Of These Comments Also Explicitly Direct The CFPB To Consider “The Detailed Feedback In The ACA International Comment Letter.”[Docket Browser Search for CFPB-2019-0022, Regulations.gov, accessed 09/18/19]

  • ACA International Is “The Largest Trade Group For The Debt Collection Industry.” “ACA International, the largest trade group for the debt collection industry, represents approximately 2,500 members, including credit grantors, third-party collection agencies, asset buyers, attorneys, and vendor affiliates, who employ more than 129,000 employees worldwide.” [“ACA International Fact Sheet,” ACA International, January 2019]

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