A Close Look at the CFPB’s Supplemental Proposal Requiring Disclosures by Debt Collectors for Time-Barred Debts

Summary: Our discussion examines a range of issues, including how the wording of the model forms could create consumer confusion, challenges in determining whether a debt is time-barred, and questions arising from use of a “know or reason to know” that a debt is time-barred standard to trigger disclosures. We also look at industry’s reaction and how the proposal’s finalization is likely to fit with the CFPB's issuance of a final larger debt collection rule.