Although on April 7, 2021, the CFPB proposed to delay the October 2020 and December 2020 Debt Collection Rules by 60 days, on April 16, 2021, the CFPB moved forward with its earlier stated plan to update the small entity compliance guide to include the December 2020 Debt Collection Rule. The update guide is available here.
As discussed earlier with respect to the October 2020 Debt Collection Rule, the small entity compliance guide provides a detailed summary of (now) both the October 2020 and December 2020 Debt Collection Rules as well as examples to illustrate portions of the rules. Such compliance guides are not “rules” under the Administrative Procedure Act, will not be used by the CPFB to make decisions that bind regulated entities, but are meant to present the rules and statutes in a manner that is useful for compliance professionals. The guide may also include practical suggestions for how covered entities might choose to comply with the rules and statutes.