Returning guest Michelle Dove, Chief Compliance Officer and General Counsel for IC System, sits down with host Tyler Kern to discuss the changes implemented by Regulation F and how they’ve affected IC System as well as the broader debt collection world.
“I am mainly tasked with understanding the law that applies to the collection industry and making sure that our practices are adhering to the law,” said Dove. So when it comes to understanding Regulation F, Dove is a go-to for IC System.
“Regulation F is a series of rules that the CFPD introduced in late 2020 and 2021,” after becoming effective in 2021, the regulations supplement “the FDCPA,” said Dove. Dove said that while some things in the regulations aren’t her favorite, “It really gives debt collectors more guidance…it really is a roadmap for IC…it tells us how to comply.”
Regulation F affects how often you can call and how to report collection, among other things. The new 7-7-7 rule means that collectors can call 7 times within a 7-day period and if they talk to a consumer, then, “we can’t call them again for 7 days after that,” explained Dove.
Credit reporting under Regulation F has also changed, “Now, in order to credit report an account, you need to communicate with the consumer first and so, that would be sending a letter,” said Dove. For IC System, “The most focus went on changes that impact out initial notice.”
While the notification was standardized before, the model sample notice given through Regulation F changed the format and information needed to adhere to this new regulation.
And while bigger agencies might have incorporated changes more quickly, IC did not have any delays in service throughout the transition, just more disputes engaged from that initial notice requirement across the board.
“It’s still a learning process,” said Dove, but learning always means improvement.