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Debt Collection – CFPB

The CFPB Debt Collection Examination Procedures cover all aspects of consumer debt collection and are applied to larger market participants as well as other entities within the supervisory authority of the CFPB.

The following modules are the active areas of controls, which will be assessed and reported on during a CFPB assessment:

Module 1 – Entity Business Model

  • Nature of operations
  • Affiliates and third-party relationships
  • Internal structure, controls, and compliance management
    • Independence and reporting structure
    • Applicable law
    • Appropriateness
    • Timeliness
    • Corrective and preventative action
  • Debt ownership or account transfers

Module 2 – Communications in Connection with Debt Collection

  • FDCPA
  • Technology
  • UDAAP

Module 3 – Information Sharing, Privacy, and Interactions with Consumer Reporting Agencies

  • GLBA and Regulation P
  • FCRA and Regulation V

Module 4 – Consumer Complaints, Dispute Resolution, and Debt Validation

  • FDCPA
  • Disputes, complaints, and inquiries management

Module 5 – Payment Processing and Account Maintenance

  • FDCPA, EFTA and Regulation E
  • UDAAP

Module 6 – Equal Credit Opportunity Act

  • ECPA and Regulation B

Module 7 – Litigation Practices, Repossession and Time-Barred Debt

  • Litigation practices
  • Repossession
  • Time-Barred Debt

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