Today EPIC submitted comments to the Consumer Financial Protection Bureau on the agency's proposed amendment to the Fair Debt Collection Practices Act. EPIC recommended that the CFPB: (1) clarify the definition of debt collector, (2) impose limitations on quantities of texts and emails, (3) not provide a safe harbor for debt collectors through limited-content messages, (4) impose liability for third-party disclosures by email or text, (5) require debt collector to offer a streamlined process for opt-out on any given medium, (6) limit the consumer information that can be included in debt validation notices, and (7) require debt collectors to comply with E-Sign Act consent requirements. EPIC previously advised CFPB on debt collector practices and the agency's publication of consumer narratives in the public complaint database.
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