Miscellaneous
We discuss a range of practical issues related to the rule’s rapidly-approaching effective date, including: the prospects for further CFPB rulemaking or guidance; the aspects of the rule that should be prioritized by third-party collectors and debt buyers; the rule’s impact on creditors (for internal collections and third-party collector/debt buyer oversight), state law considerations, and steps being taken to mitigate risk; and greatest risks for third-party collectors and creditors once the rule is effective. Chris Willis, Co-Chair of Ballard Spahr’s Consumer Financial Services Group, hosts the conversation, joined by Stefanie Jackman and John Culhane, partners in the Group.