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Comments Regarding CFPB’s Advanced Notice of Proposed Rule Making – Debt Collection (Reg F)

February 28, 2014

Consumer Financial Protection Bureau
Attention: Monica Jackson
Office of the Executive Secretary
1700 G Street NW
Washington, DC 20552

Re: CFPB-2013-0033-0001, Advanced Notice of Proposed Rule Making – Debt Collection (Regulation F)

Dear Ms. Jackson:

Young Invincibles (YI) appreciates the opportunity to comment on the Consumer Financial Protection Bureau’s (CFPB) Advanced Notice of Proposed Rulemaking (ANPR) on debt collection (Regulation F). We are a non-profit advocacy organization working to advance economic opportunities for young adults 18 to 34 in the areas of higher education, jobs, and health care.

Recently, a young woman named Cara from Florida wrote to us about her challenges with debt collection. She graduated from the University of Miami with a degree in electrical engineering. Several unforeseen events led her to default on her student loans. For eighteen months, Cara tried everything she could to rehabilitate them. She wrote to debt collection agency after agency to no avail. Agencies sold her loans back and forth several times, and when she tried to contact them to sort things out, she told us that the debt collectors refused to respond to her requests or give her any information. When Cara was six months pregnant with her first child, a collection agency started garnishing her paychecks. When Cara contacted YI, she barely had any money to support her family or feed her baby. The collection agency still refused to return her calls or letters. She tried to buy a home for her new family but the mortgage company denied her mortgage because of her credit. She feels powerless because she cannot take care of her aging parents or even open a simple checking account. Cara feels like a prisoner to her loans.

This is one borrower’s story, but it illustrates how debt collection practices can make a trying situation for a young borrower much worse. And Cara is not alone. Currently, thirty-seven million student loan borrowers have outstanding balances that total over $1 trillion.[1] Over five million borrowers have at least one past due student loan account, with a whopping $85 billion past due.[2] Student loan collection is a hefty portion of the debt collection industry: in 2011, a national trade association of collectors reported that student loan debts were among the most frequent debts on which collectors seek to recover from.[3]

[1] Young Invincibles, “College Affordability Facts,” (last visited February 28, 2014).

[2] Ibid.

[3] ACA International, 2011 Top Collection Markets Survey: For Period: Jan.1, 2010-Dec. 31, 2010 at 9 (2011), available at