We’re pleased to share a significant regulatory update that reflects the power of industry advocacy and the importance of collaborative action.

The Consumer Financial Protection Bureau (CFPB) has announced it will revoke its advisory opinion on medical debt collection, following legal challenges and industry pushback—including advocacy efforts led by ACA International and supported by key partners like State.

This development is a major step toward restoring clarity and fairness in the regulation of medical debt collection. The CFPB’s advisory opinion, issued in late 2024, had raised concerns across the industry due to its overreaching guidance, which conflicted with existing laws such as the FDCPA and Regulation F.

State joined ACA and others in voicing strong opposition, advocating for the withdrawal of the advisory opinion in courts, through legislative channels, and via direct engagement with regulators. As a result of these efforts, the CFPB has agreed to stay the litigation while it proceeds with revocation.

Key Important Factors:

• The CFPB’s advisory opinion would have imposed additional, unnecessary obligations on medical account servicers and debt collectors.
• The court has affirmed that the advisory opinion does not have the force of law and is largely suggestive, not mandatory.
• The decision to revoke it acknowledges that the CFPB’s previous actions already address concerns related to medical debt collection.

Looking Ahead

State will continue working closely with our industry partners to monitor and respond to regulatory changes, ensuring our clients remain informed and compliant without being burdened by unnecessary policy shifts.

This is a clear example of how targeted, strategic advocacy can produce meaningful results for our industry—and ultimately benefit consumers by preserving fair, effective practices.