Compliance with CFPB Regulation F
As you are likely aware, the Consumer Financial Protection Bureau (CFPB) has published rules regarding the Fair Debt Collection Practices Act (FDCPA). As your collection partner we are diligently working through implementation of the new rules which go into effect on November 30, 2021.
Against this backdrop, we have modified our Validation/First Notice to coincide with the directive of the CFPB. The CFPB’s new Model Validation Notice requires debt collection agencies to utilize an “itemization date” for the purposes of providing consumers a debt detail. The debt detail will provide the balance of the debt at the itemization date, any interest or other fees assessed from the itemization date until the date of placement, and any payments or credits to the account from the itemization date until the date of placement.
Accordingly, State will require additional information in your new business listings to comply with the new rules. We have put together a handout to walk you through the required information needed. You can access that document by clicking here.
In addition, effective November 15, 2021 all clients will be required to utilize a listing spreadsheet to list your new business accounts. We will no longer be accepting account placements via State Online or by sending over account details. State Online will still be available for your other servicing needs. We are making updates to the current listing spreadsheet and will make that available to our clients as soon as our system is updated to accept the new format.
In the event you are unable to provide the required information, we will not be able to process, accept or work your new business listings after November 29, 2021. We will return accounts without sufficient information in order to ensure our mutual compliance with the new federal regulations.
If you have any questions or concerns regarding this request, please do not hesitate to reach your SCSI account representative or call us at 800-477-7474 ext. 190.