How will debt collection proposal affect CUs?

As the CFPB considers a rulemaking related to third-party debt collection, NAFCU would like to know how it could impact credit unions that use third-party vendors or credit union service organizations (CUSOs) to collect debts owed.

Although rulemakings for both first- and third-party debt collection were initially contemplated, the bureau’s focus shifted to just third-party. However, a first-party debt collection rule is still possible in the future. NAFCU previously urged the bureau to exempt credit unions from any rules related to first- and third-party debt collection, as credit unions are not the bad actors in this space.

In a Regulatory Alert sent to member credit unions Thursday, NAFCU outlined that the proposal would:

  • create a new limited-content message and allow debt collectors to communicate with consumers through email, text message and social media (only through private messaging functions), though the debt collector must include instructions to opt-out of receiving communications via email or text message;


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