Limited Content Messages under the CFPB's Proposed Debt Collection Rule
Our podcast looks at challenges arising from the CFPB's proposal to allow debt collectors to leave a limited content phone message that would not violate the FDCPA's third party disclosure prohibition. In addition to the requirement for a collector to leave the name of a natural person for the consumer to contact, we discuss the proposal’s prohibition on leaving the collector's name, the CFPB's rationale, potential state law concerns, and implications for first party collections.