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CFPB Notice and Opportunities - Calls for Public comments

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https://www.consumerfinance.gov/policy-compliance/notice-opportunities-comment/

 

 

The Consumer Financial Protection Bureau is issuing a call for evidence to ensure the Bureau is fulfilling its proper and appropriate functions to best protect consumers.

 

The Bureau will be publishing in the Federal Register a series of Requests for Information (RFIs) seeking comment on enforcement, supervision, rulemaking, market monitoring, and education activities. These RFIs will provide an opportunity for the public to submit feedback and suggest ways to improve outcomes for both consumers and covered entities

 

individual links to below can be found at the main links above

 

 

This SHOULD NOT have to become political - it's just very, very simple

 

 

Consumers voices need to be heard or we will be letting the banks and debt collectors comments drown us out

 

please avoid any political comments to keep this thread open and current

 

 

 

Basically Banks, CA's and JDB's want to squirm out of CFPB rulings on Federal law violations

 

Back before the CFPB the OCC and FDIC did dipsquat about consumer complaints and sat on regulatory actions for years

 

When the CFPB first started, they grabbed a bunch of Credit card related violations that the OCC was sitting on and MOVED

 

 

The first enforcement actions that the CFPB made against Capital One, Discover, AMEX and Chase had all been subject of consumer complaints to the OCC which they had been " investigating " of a couple of years and did nothing to stop

 

The FTC did not have a regulatory power to make and enforce new rules on the FDCPA , or require JDB's and CA's to turn over their records

 

The FTC case against Asset Acceptance took 8 years of complaints and 2 1/2 years of investigations before they were stopped, and even after that the FTC couldn't issue any nationwide regulatory actions making the JDB's stop this practice

 

In the meantime they were threatening, harassing and filing suits on debts that were well past the legal Statute of limitations

 

Over the past years that the CFPB has been in action, I've notice a BIG Drop in complaints on this board about the top JDB's and CA's

 

They have all had to revise their illegal business practices because the CFPB had supervisory powers to walk in ANY Bank, JDB of CA office and demand documents and records

 

 

 

IF WE DON'T COMMENT, THE CFPB IS GOING TO LOSE THIS AUTHORITY AND WE AND ALL UNINFORMED CONSUMERS WILL SUFFER FOR IT BECAUSE THE AFFECTED PARTIES WILL REVERT RIGHT BACK TO THE SOS.

 

 

 

Request for Information Regarding Bureau Rules of Practice for Adjudication Proceedings

 

( Banks and JDB's just don't like the CFPB enforcing federal laws and fining them when they break it - they would like to let this drag out in individual court proceedings that take years, which has no nationwide ramifications on the entire industry )

 

 

Request for Information Regarding Bureau Civil Investigative Demands and Associated Processes

 

( Same deal as above - and they don't want to turn over any records that prove they were breaking the laws. )

 

Request for Information Regarding Consumers’ Experience with Free Access to Credit Scores

 

( sounds like the CRA's are crying over losing fees for this ? )

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I had a long conversation with someone at the CFPB and was basically told I could file complaints until the cows come home and nothing can or will be done unless over 200 other people complain about the same company that is doing the same thing to others.

 

Basically what I was told was you my dear consumer don't matter with your one little ole complaint.

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I had a long conversation with someone at the CFPB and was basically told I could file complaints until the cows come home and nothing can or will be done unless over 200 other people complain about the same company that is doing the same thing to others.

 

Basically what I was told was you my dear consumer don't matter with your one little ole complaint.

Just assume you are number 200

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Yeah, Well I have posted in the past that one shouldn't file complaints over "Technical Violations" of the FCRA

 

ie; where you legitimately owe a debt, and you're attempting Credit repair by utilizing some technical reporting error :

 

JDB isn't a Factoring company,

 

listing the incorrect original creditor

 

the account was never delinquent with that Creditor listed

 

 

**IT AIN'T GONNA FLY GIRL, CAUSE THE CFPB HAS MORE IMPORTANT STUFF TO DO.

 

CFPB complaints database are just littered with these types of complaints. I suppose the reps at the CFPB have shared stories about it and have a top ten list going.

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Seems to me y'all are misinterpreting the point. The CFPB is taking comments and evidence regarding their mission - not individual complaints filed by consumers.

 

Comments should be broad, and point to systemic abuses or patterns of abuse and suggestion on how the CFPB can better respond to consumers. We should not be using this for everything. Remember "the boy who cried wolf?"

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Seems to me y'all are misinterpreting the point. The CFPB is taking comments and evidence regarding their mission - not individual complaints filed by consumers.

 

Comments should be broad, and point to systemic abuses or patterns of abuse and suggestion on how the CFPB can better respond to consumers. We should not be using this for everything. Remember "the boy who cried wolf?"

Yes. And the girl who cried wolf. Happens all too often.

 

Will the JDB and CAs also not be attempting to use this opportunity for their gain, to also try to make the CFPB useless?

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NOW IT'S THE ENFORCEMENT PROCESSES

 

 

https://www.consumerfinance.gov/policy-compliance/notice-opportunities-comment/open-notices/call-for-evidence/

 

 

The Consumer Financial Protection Bureau is issuing a call for evidence to ensure the Bureau is fulfilling its proper and appropriate functions to best protect consumers. The Bureau will be publishing in the Federal Register a series of Requests for Information (RFIs) seeking comment on enforcement, supervision, rulemaking, market monitoring, and education activities. These RFIs will provide an opportunity for the public to submit feedback and suggest ways to improve outcomes for both consumers and covered entities.

 

FIFY

 

 

The Consumer Financial Protection Bureau (CFPB) today issued a Request for Information (RFI) about administrative adjudications. The Bureau is seeking to better understand the benefits and impacts of its use of administrative adjudications, and how its existing process may be improved.

 

 

 

 

The next RFI in the series will address the Bureau’s supervisory processes, and will be issued next week.

 

 

bleh

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The CFPB has had a pretty positive effect overall. Their mission is both pro business and pro consumer. It's not in legitimate businesses interest to have scammy collectors and abuses by the larger ones seem down over the last 5 years. OTOH, abuses by the fly by nighters are up or at least seem to be. There are no end of ones that call making threats of arrest and other grossly illegal things. The problem is these are small operations. They want to be paid with a debit card and they can't even be found for the most part. The CFPB, like the SEC, is a civil agency with limited resources and they prioritize based on the entities doing the most damage where their power is significant. The CFPB does not have regulatory control writ large and much of their power is limited to entities of a statutory size.

 

So report things that are significant abuses and save them time. It helps them make their case too.

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The CFPB does have rule making and supervisory authority that the FTC never had

 

they hit the CC Banks first, moved onto Mortgages, the JDB's and payday loans,

 

they were just moving on to new FDCPA rules

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The CFPB does have rule making and supervisory authority that the FTC never had

 

they hit the CC Banks first, moved onto Mortgages, the JDB's and payday loans,

 

they were just moving on to new FDCPA rules

They certainly do have expanded authority within the consumer universe. But they only have supervisory authority of banks, CUs, etc of 10B or more in assets, as well as the larger CRAs. They have pretty much unlimited supervisory powers over payday loans, mortgage originators, and similar critters of any size. A great deal of their work is focused on data collection designed to prevent a recurrence of the 2008 meltdown but many of the initial Dodd Frank restrictions have been eased or dropped. An example I've mentioned from time to time is the CFPB final rule that says that portions of student loan proceeds can be counted towards income when applying for credit. That's just weird.

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