This Note proceeds in five parts. Part II outlines the primary differences between third-party debt collectors and first-party lenders. Part III provides an overview of current regulations of third-party debt collectors and first-party lenders, specifically relating to "unfair, deceptive, and abusive [acts or] practices." Part IV explains the areas in which the ANPR suggests changes in regulation, particularly as those changes apply to first-party lenders. Part V discusses whether regulation of first-party lenders is statutorily feasible, or even necessary, and addresses some of the practical barriers to such regulation. Part VI concludes by arguing that, while additional regulation of first-party lenders and their debt collection practices is possible, the CFPB’s proposed method is not practical because this type of regulation requires more individualized consideration.
Who’s Your Debt Collector Now? Extending Debt Collection Regulation to First-Party Lenders,
N.C. Banking Inst.
Available at: http://scholarship.law.unc.edu/ncbi/vol19/iss1/17