Countdown to Reg F - Still have Questions for the CFPB? There's a Portal for That.

There are 43 days left until November 30, 2021, when Regulation F (Reg F) goes into effect. Excluding weekends and Thanksgiving, there are only 30 (yes... THIRTY) business days left for ARM entities to ensure they are ready to comply with the new requirements. 

Last week, we wrote about the actions creditors need to take to ensure that their accounts will continue to be collected after November 29, 2021. This week, we'd like to bring attention to Consumer Financial Protection Bureau (CFPB) resources that ARM entities may find helpful as they continue to work toward complying with the rule. 

Questions portal

The CPFB has a portal where entities can submit questions regarding CFPB rules (including Reg F) directly to the Bureau's Office of Regulations. The CFPB will respond in 10-15 business days, and they will let you know if they need more time. Although responses are not official interpretations and are not a substitute for legal counsel, they can be helpful for guidance. Additionally, submitting questions through this portal will allow the CFPB to see whether certain portions of Reg F are more confusing than others and may need additional explanatory materials.

Plain language and other guidance materials

In addition to allowing the public to submit questions directly through the portal, the Office of Regulatory Implementation and Guidance provides plain language materials to help people understand the CFPB's rules. 

These resources include:

• Executive summaries
• FAQs
• Fact Sheets
• Compliance Guides
• Webinars
• Coverage Charts

Updates regarding the Rules

The CFPB has also provided a means for people to receive updates regarding debt collection rules via email. You can sign up for updates from the CFPB regarding Reg F here  (make sure to scroll down for "Rules related to debt collection"). 

insideARM Perspective:

The effective date of Reg F is right around the corner; it will be here before we know it. Many ARM entities continue to struggle with how to interpret and implement the rule in the safest and most effective manner. Although these resources have been offered by the CFPB for quite some time, their existence may not be common knowledge. They may help provide guidance on interpretation and implementation challenges, and with November 30th right around the corner, ARM entities that were not previously aware of these tools may want to look at them sooner rather than later.