Here. The staffer, Ronald L. Rubin, has also served as senior counsel to the House Financial Services Committee and as a partner at a big law firm. Excerpts:
Nobody should be charged, harassed, or sued for a debt they've already paid or for someone else's debt. However, the CFPB's proposed solution is a hopelessly complex system of debt validation requirements and procedures—with rounds of notices, statements, information requests, and document transfers between debtors, creditors, and debt collectors. The new rules will create so many loopholes that debtors with [clever] lawyers . . . will never pay a dime, and may even get rich suing collectors.
The CFPB could prevent mistaken debt collection attempts far more effectively and efficiently by creating and maintaining a central debt registry * * *
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The CFPB won't consider the debt registry solution for two reasons. First, like the bureau's Internet complaint database, it would be a big project. The agency might have to repurpose the tens of millions of advertising dollars it spends promoting itself each year. Second, the registry would eliminate uncertainty and make it harder for consumers to avoid paying legitimate debts. Heaven forbid.