CRC Proposes Comprehensive Solution to Consumer Communications Challenges

Earlier this month the Consumer Relations Consortium (CRC) submitted a proposal to the Bureau of Consumer Financial Protection (BCFP or Bureau) to address the need for debt collectors to initiate communications with consumers through modern communication methods. While this topic has been a focus of discussion since the Bureau’s 2013 Advance Notice of Proposed Rulemaking, the environment changed materially since that time and continues to evolve rapidly. In addition to consumers’ movement away from landline phones, postal mail and fax and toward email, texting and mobile communications, a crisis of trust has emerged which presents unique challenges to the debt collection industry.

Overview of the Full Range of the Problem

Because of the proliferation of scams through the mail, the phone and online, a majority of consumers do not trust anyone unknown who is seeking to contact them. Regulators, consumer groups and the media regularly advise consumers a) not to respond to unknown callers, and/or b) not to provide any sensitive information to someone they don’t know.

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