Mike Ginsberg, President & CEO of Kaulkin Ginsberg, and Rozanne Andersen, Vice President & Chief Compliance Officer of Ontario Systems, recently got together to discuss some of the most important compliance related topics affecting ARM companies in today’s market including the CFPB’s new rules under consideration, last months SBREFA hearing, credit reporting trends and TCPA rulings. Here is a link to the podcast.
According to Rozanne, "decision making has been stifled as executives of ARM companies across the country try to interpret the new rules under consideration from the CFPB." She strongly believes that ARM companies need to have a deep understanding of the rules under consideration and begin to address any gaps in their operation regarding these rules, regardless of size since regulators aren’t necessarily hearing the voices of small and midsize ARM companies. In addition, the current SBREFA outline is, probably, pretty close to what we’re going to eventually see as the final rules so there is no point in waiting to address operational deficiencies.
Also, Mike and Rozanne addressed the industry-held belief that if an agency has few, or no, complaints on the CFPB consumer complaint portal, then they would not be impacted by the rulings – a belief that may prove to be costly.
Lastly, they covered the costs of compliance, much of which can be outsourced to third-party specialists and the critical items ARM companies need to address as we head into the New Year, including the practice of convenience fees, statute of limitations on time barred debts, and potential liability regarding the data ARM companies submit to credit reporting bureaus.
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