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Volume 25 - Number 6

March 17, 2014

Groups Oppose Applying FDCPA to First Party Creditors Under UDAAP

Three lender-related trade groups told the CFPB they are opposed to the wholesale extension of the Fair Debt Collection Practices Act to first-party creditors using the bureauís rulemaking authority to prohibit unfair, deceptive or abusive acts and practices. Commenting on the bureauís advance notice of proposed rulemaking on debt collection practices, the American Bankers Association, the Consumer Bankers Association, and the Financial Services Roundtable said they support the CFPBís decision to initiate a rulemaking in the space, given the massive consumer debt market now stands at $11.8 trillion and the importance debt collection has for credit availability.

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With originations expected to drop in 2018, will your shop turn to non-QM/non-prime mortgage products as a way to bolster volumes?

Yes, definitely. We’re planning a launch.
No. It’s still difficult compliance/regulatory-wise.
Maybe. It’s under consideration.
Not now. But things could change as 2018 progresses.

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