I. INTRODUCTION
The Consumer Financial Protection Bureau (CFPB) put companies on notice through the issuance of bulletins advising that all companies under the Bureau’s jurisdiction will be held accountable for unlawful conduct in collecting a consumer’s debts. Many collection firms play by the rules and treat consumers fairly, but those that do not can cause financial harm to consumers and undermine the marketplace. Banks and other creditors may collect their own debt. They also may hire a debt collector or sell the debt to third parties. Those third-party debt buyers may collect the debt themselves or sell it again.
II. CFPB BULLETINS ON PRACTICES IN THE DEBT COLLECTION MARKET
The CFPB published two bulletins on debt collection. The first makes clear that any entity subject to the Consumer Financial Protection Act of 2010, whether a third-party collector or a creditor collecting its own debts, can be held accountable for any unfair, deceptive, or abusive practices in collecting a consumer’s debts. The second warns companies to avoid deceptive statements concerning the impact of paying a debt on a consumer’s credit score, credit report, or creditworthiness.