The Consumer Financial Protection Bureau’s (CFPB) proposed mandatory disclosures for time-barred debt collection will not adequately protect consumers. This proposed rule will serve as legal cover for debt collectors who engage in the inherently unfair, deceptive and abusive practice of collecting time-barred debt which is an aggressive effort to pursue the collection of legally unenforceable debt. Instead of finalizing this rule, we urge the CFPB to prohibit all collection of time-barred debt. However, if the CFPB does not adopt a necessary ban, and instead retains disclosures, the CFPB must improve those disclosures to protect consumers and should ensure that its rule applies a strict liability standard.
