According to the Federal Register website, Regulation F — the Consumer Financial Protection Bureau’s (CFPB) final rule on debt collection —is now published in the federal register. This means that the clock is officially ticking towards the effective date: November 30, 2021.
Questions remain about the finality of the final rule, but with no definitive answers, and only speculation based on the election results and potential changes in Congress. The CFPB has published Regulation F – or at least Part 1 of Regulation F – on October 30 of this year after a seven-year rule-making effort. The CFPB reserved certain sections of the rule, including those on disclosures and the validation notice, for Part 2, which is scheduled for publication in December 2020.
Whether the Part 2 disclosure rules will have the same effective date as Part 1 remains to be seen. The Administrative Procedures Act requires a minimum of 30 days from publication in the Federal Register before a rule can come into force. The one-year effective date of Regulation F is likely related to its complexity and the time the CFPB estimates it will take to implement. This is pure speculation, but the CFPB may decide to make the full rule – parts 1 and 2 – effective on the same date for simplicity.
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InsideARM perspective
insideARM will post an FAQ document for Regulation F later today. This is a free resource for members of the insideARM research assistantship program. For those who are not members and do not wish to join Research Assistant, you can pre-order your copy here for $129. It will be emailed to you when it is released.
