The Bureau of Consumer Financial Protection has the opportunity to streamline its regulatory and supervisory processes as it continues the review of its core functions this year, as noted by ACA International in comments on its Guidance and Implementation Support Request for Information.
This is a key opportunity to shape how compliance guidelines and regulatory updates are communicated to companies in the accounts receivable management industry and regulated entities, especially since the BCFP and Federal Trade commission have separate rulemaking and enforcement authority, respectively. “As explained in prior ACA RFI responses, when Congress passed the FDCPA in 1977 it provided the Federal Trade Commission (FTC), then the primary regulator for the FDCPA, with enforcement authority only, but no rulemaking authority. The result has been 40 years of inconsistent interpretation of the law by the courts,”
ACA International CEO Mark Neeb said in comments filed to the BCFP July 2. The BCFP, since its inception, has provided guidance through a variety of means, and its guidance and implementation support functions are continuing to evolve in response to feedback from industry and other stakeholders, according to the RFI, ACA International previously reported.
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