The Consumer Financial Protection Bureau last week issued a final ruling on what constitutes fair debt collection behavior when communicating with consumers and outlined what is prohibited under that definition.
While lenders aren't third-party debt collectors, American Financial Services Association leaders voiced concerns this year that its membership could end up being similarly restricted.
AFSA said in January its members were wary of the fact the bureau included in its proposed amendments a mention of the CFPB's authority around violations of UDAAP — unfair, deceptive or abusive acts or practices — in crafting the changes to the rule. While the updated rule no longer calls upon the bureau's UDAAP authority, it may provide a framework for state legislatures and regulators to impose new restrictions on creditors down the line.
Celia Winslow, senior vice president at the American Financial Services Association, said in a statemen…