The Difference Between Holding a License and Keeping It

Terri Haley
Director of Compliance, the iA Institute

In the past, the majority of ARM industry focus on regulatory oversight was with the federal government’s enforcement of the FDCPA.  Originally these reviews were conducted primarily by the FTC.  Then came the origination of the CFPB and its publications on UDAAP, so we had to start taking a more in-depth look at everything we do that could possibly have a negative impact on consumers.  Without the specific guidelines language given by the FDCPA our internal reviews have hopefully become broader in scope and more thoughtful overall.  At the same time these changes were taking place we began to see a significant increase in oversight by individual states.

Holding a license and keeping it current are no longer enough to pass muster.  Many states now conduct extensive audits of collection agencies, law firms and debt buyers who are communicating with consumers living within their borders.  The states continue to evaluate and expand the laws governing this activity.

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