Comments sbwaddell Endorsed

Consumer Debt Collection Practices (ANPRM) | Closed Rule

josephusmyer
1

To avoid consumers getting sued repeatedly on the same debt, the CFPB should require or encourage states to adopt rules requiring that judgments be preclusive of future consumer-collector litigation on the same debt; instead, if there is a dispute between assignees as to who has title to the debt, they should work it out between themselves instead of risking subjecting the consumer to multiple liability.

josephusmyer
2

Assignments without notice could lead to consumers paying the wrong person. The CFPB should encourage proper notice by ruling that a payment made to either of the assignee or the assignor reduces the debt.