The National Installment Lenders Association (NILA) this week submitted a comment letter to the Consumer Financial Protection Bureau (CFPB) on the topic of the bureau’s proposed rule to amend Regulation F, 12 CFR part 1006, which implements the Fair Debt Collection Practices Act (FDCPA).
In our comments, NILA recognized the need for string and effective consumer protections as applied to debt collections, but raised concerns about the rule’s potential to affect installment lenders’ own ability to collect on their loans.
NILA made a number of suggestions to mitigate this, most significantly calling for the rule making to recognize and describe the differences between third-party debt collectors and creditors collecting their own debt.
The full text of NILA’s letter can be seen at the link below: