Many adjectives can describe this year for the ARM Industry. Dynamic may be the most appropriate given the full implementation of Regulation F and the over-expanding authority of the Consumer Financial Protection Bureau (CFPB). 2022 was a year of “initiatives” and policy statements which will translate into affirmative action by both the CFPB and state regulators. Unlike 2020 and 2021, ARM Industry participants saw a decline in placements but an uptick in scrutiny upon credit reporting and the collection of medical debt. By the middle of the year it was apparent that unfair, deceptive and abusive acts and practices (“UDAAP”) were not only going to dominate the conversation but be transformed into a tool that would tackle discrimination. Below is the good, the bad, and the ugly of the year that was.
Reg F is Yesterday’s News
Whether you like it or hate it, Reg F brought regulatory consistency to the industry. Although some of the Reg F requirements were difficult to implement, like the Model Validation Notice, finally having regulations that clarify and interpret the Fair Debt Collections Practices Act (FDCPA) was a welcome change. FDCPA lawsuits still continued on a downward trajectory. Although we are seeing some lawsuits challenge the Reg F requirements, they are few and far between.
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