Per the Federal Register's website, Regulation F—the Consumer Financial Protection Bureau's (CFPB) Final Rule on debt collection—is now published in the Federal Register. This means that the clock is officially ticking toward the effective date: November 30, 2021. 

Questions remain as to how final the Final Rule is, but with no definitive answer, and really only speculation based on the results of the election and potential shifts in Congress. The CFPB released Regulation F—or, at least, Part 1 of Regulation F—on October 30 of this year after a seven-year-long rulemaking effort. The CFPB reserved certain sections of the rule, including those on disclosures and the validation notice, for Part 2, which is scheduled for release sometime in December 2020.

Whether or not the disclosure rules of Part 2 will have the same effective date as Part 1 is yet to be seen. The Administrative Procedures Act requires a minimum of 30 days from publication in the Federal Register before a rule can go into effect. The one-year effective date of Regulation F likely pertains to its complexity and how long the CFPB believes it will take to implement. This is pure speculation, but the CFPB might decide to make the full rule—parts 1 and 2—effective on the same date for the sake of simplicity.


insideARM Perspective

insideARM will be publishing an FAQ document for Regulation F later today. This is a free resource for members of insideARM's Research Assistant program. For those not members, and not interested in joining Research Assistant, you can pre-order your copy here for $129. It will be emailed to you when it is released.

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