Is it possible to just allow consumers to opt out of certain kinds of communication entirely? Does CFPB have authority to require opt-out at any point during the process? They could set transparent, limited rate increases which debt collectors could charge for each mode of communication that is eliminated. A rule setting that kind of rate increase would add some necessary transparency to the question of whether these kinds of communications are even worthwhile for the agency.
There's no need to be rude about it. There are some debt collection practices that should obviously be illegal. Other things that people are discussing here are obviously matters of convenience. To the extent that preferences are widely shared and outright prohibition wouldn't increase lending costs across the board beyond a marginal amount, outright prohibition makes sense. But if someone wants the ability to stop someone from conducting any and all robocalls from all phones, and robocalls help creditors recoup their loans, then the creditor should be able to charge a regulated fee for that convenience. I'm not saying that the debt collection agency itself would charge the fee (although my late-night post stated otherwise). Just that a consent-based approach is another option.
DannyF
1
Is it possible to just allow consumers to opt out of certain kinds of communication entirely? Does CFPB have authority to require opt-out at any point during the process? They could set transparent, limited rate increases which debt collectors could charge for each mode of communication that is eliminated. A rule setting that kind of rate increase would add some necessary transparency to the question of whether these kinds of communications are even worthwhile for the agency.
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DannyF
2
*Are even worthwhile for the _debt collection_ agency...
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DannyF
3
There's no need to be rude about it. There are some debt collection practices that should obviously be illegal. Other things that people are discussing here are obviously matters of convenience. To the extent that preferences are widely shared and outright prohibition wouldn't increase lending costs across the board beyond a marginal amount, outright prohibition makes sense. But if someone wants the ability to stop someone from conducting any and all robocalls from all phones, and robocalls help creditors recoup their loans, then the creditor should be able to charge a regulated fee for that convenience. I'm not saying that the debt collection agency itself would charge the fee (although my late-night post stated otherwise). Just that a consent-based approach is another option.
View this comment in the discussion thread