Dear Director Cordray:

The undersigned consumer protection, civil rights, and legal services groups write to express our significant concerns with the outline of proposed regulations on debt collection issued by the Consumer Financial Protection Bureau on July 28, 2016. The proposal represents a missed opportunity to fundamentally improve protections for consumers victimized by predatory debt collection practices.

Some of the proposed changes will address certain debt collector conduct that hurts consumers. For example, we support the CFPB’s proposal to: 1) require the transfer of information from prior attempts to collect the debt, 2) prohibit collectors from “parking” debts on credit reports without informing the consumer about the debt, 3) require collectors to tell subsequent collectors about unresolved disputes, and 4) require the resolution of those disputes before collection activity can continue. However, significant aspects of the outline fall far short of the reforms needed to protect consumers from abusive debt collection practices.