A&O Comments on Proposed Rule on the Fair Debt Collection Practices Act

Dear Director Kraninger,

We are contacting you in regards to the CFPB’s proposed rule on the Fair Debt Collection Practices Act (FDCPA). Thank you for the opportunity to submit comments on this matter. The Fair Debt Collection Practices Act is critical to protecting consumers across the nation from abusive collection practices. However, we believe the newly proposed rule would protect debt collectors more than everyday American consumers. We urge the CFPB to protect consumers by promoting fair debt collection practices.

According to the National Consumer Law Center, the median debt owed by Hoosiers is $1,509; the majority of debt is related to medical expenses or student loans. In Indiana, 34 percent of all Hoosiers have a debt in collections. This figure balloons to 56 percent of Hoosiers with a debt in collections when viewed through the lens of those living in communities of color.

In 2016, your office fielded 8,348 complaints by Hoosiers regarding abusive debt collection practices, including (but not limited to) calling after receiving a “stop calling” notice; repeated calls; making false representation about debts; failing to identify self as a debt collector; falsely threatening illegal or unintended act; and more.

Given the fact that Indiana's current laws do not provide sufficient protections against predatory debt collection practices, we implore the CFPB to protect consumers by shielding them from abusive practices. A revised rule that aims to protect consumers would: limit the number of calls and texts received by consumers from collectors; provide clear delinquency notice to consumers; and reduce the number of harassing messages from collectors.

Thank you for the opportunity to comment. For further clarification on these comments, please contact Logan Charlesworth, Indiana Assets & Opportunity Network Manager, at lcharlesworth@prosperityindiana.org or (317) 520-1546.

Sincerely,
Indiana Assets & Opportunity Network (Indianapolis)
Prosperity Indiana (Indianapolis)
Fair Housing Center of Central Indiana (Indianapolis)
Marion County Commission on Youth, Inc. (Indianapolis)
Homestead Consulting Services (Lafayette)
Lisa Laflin/West Indianapolis Development Corp. (Indianapolis)
Habitat for Humanity of Indiana (Indianapolis)
Indiana Association of Area Agencies on Aging (Indianapolis)
Indiana Institute for Working Families (Indianapolis)
Citizens Action Coalition of IN (Indianapolis)
Indiana Coalition Against Domestic Violence, Inc (Indianapolis)
Mark A. Russell/Indianpolis Urban League (Indianapolis)
Glenn Tebbe/Indiana Catholic Conference (Greensburg)
Barbara Bolling-Williams/Indiana State Conference of NAACP (Gary)
BG James L. Bauerle/The Military / Veterans Coalition of Indiana (Carmel)
Rev. Soozi Whitten Ford/American Baptist Churches of Indiana & Kentucky (Greenwood)
Megan Miller/Providence Housing Corporation (West Terre Haute)
Steve Morrison/StarkePulaski Habitat for Humanity, Inc. (Winamac)
Mark Lindenlaub/Thrive Alliance (Columbus)
Lisa Wilken (Westfield)
Joel Zwier (Goshen)
Kaytlin Eastes (Indianapolis)
David B Menzer (Indianapolis)
Catherine Vest (Indianapolis)
Mark Tarpey (Indianapolis)
Steven A. Bramer, Jr. (Hammond)
Kathryn Thompson (Bloomington)
Cynthia J. Benedict
Jane Stowe
Chris Kerstiens