CFPB – No One is “Too Small”

The Consumer Financial Protection Bureau (CFPB) is now accepting consumer complaints against debt collectors via their web portal ( and I have been through a couple of training sessions learning how to respond, what is expected, and what the CFPB will be doing on their side.  I would like to back up a few months and share some of the things on many owners’ minds about how they were going to deal with the CFPB.

In February 2013, I attended a meeting of leaders for our national trade association (ACA International) and the CFPB was THE MAIN topic.  At the time, no one was certain what was going to happen, how the complaint process was going to work, and how they were going to be able to process the 150,000+ complaints the FTC receives on debt collectors annualy, but also respond to them in some fashion.  Over half of the 2800+ third-party debt collectors in our trade association have less than 50 employees.  The phrase I heard the most was “under the radar” as these smaller operators were hopeful the new federal regulator would not be able to find such a small company and go after them.

I can personally assure you I do not beleive this will be the case.  All debt collectors will be required to sign up with the CFPB so they can monitor and receive complaints via their portal.  After siging up, the debt collection company will need to fill out an on-boarding form with several details about the operations and corporate structure.  I received a personal phone call from someone in the CFPB office about my on-boarding form!  They had a question about one of our dba’s, but the point was clear:  there is no “too small”.    That said, I am glad to see it.  If there is going to be a new federal regulator, and if they are going to have significant power and authority, and if they are truly interested in protecting consumers, then they have a need to apply their rules to ALL players in the marketplace, not just the big guys.

I receive three emails from their office every day with spreadsheets on current, open, and closed complaints (none so far!).  The collection companies will be required to respond to any complaint (defined as “a consumer’s statement of dissatisfaction”) within 15 calendar days, and close the complaint within 60 calendar days.  Failure to do so may result in an investigation.

The portal is similar to the BBB complaint process, but has a few more features which should make it easier for both the consumer and company to interact.  I am not a fan of the low threshold defining a complaint, as it will mean having to spend resources responding to people who just don’t want to pay their bills, but I am glad to see that everyone will be playing by the same rules.

After another five months of working in the system, we’ll see if companies are still “too small” or “under the radar”, or if the new federal regulator is really making a difference for all consumers, including those who do pay thier bills as agreed and on time, not just those who want to make a “statement of dissatisfaction” about something.

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