The Consumer Financial Protection Bureau (CFPB) is implementing dramatic new regulations on collection agencies, effective November 30, 2021. We are finalizing our new process to comply with these new regulations.
For the most part this should not affect how we provide service to you. However, there is some additional information we will need from you to continue to collect on your past due accounts. This includes:
- An official charge off date. A charge off date is an accounting term that must be verifiable. The CFPB made it quite clear that the use of the date referred to collections will raise red flags worthy of an audit.
- Any interest charged by you after the charge off date must be included as a separate line on your referral. Please include any fees that your business has added in the interest field.
- Any fees added must be agreed upon in the original contract creating the debt and signed by the debtor. We cannot accept any accounts with fees that have not been agreed to in writing by the debtor.
- Any payments or credits made after the charge off date. The payment or credit amount must be included as a separate notation.
We have enclosed a copy of the new CFPB required first notice. We will be using the charge-off date as the “as of date,” This is the new date you must provide, this is different than the date of service. This “as of date” should be after all internal billing and collection activity has been completed.
Please sign this addendum stating that you have received and agree to the new terms and conditions. No other changes to your original contract with CBF have changed. However, without this CBF or any other collection agency operating in the United States will be unable to legally collect on your past due accounts. This addendum must be signed before we can collect on any account after November 30, 2021.
Thanks for your business, we truly appreciate you and hope we can make this federally mandated adjustment with as little disruption as possible. If you have any questions, please contact us at [email protected] or call at 505-325-5055 and ask for Sean.