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,

Members of the Indiana Assets & Opportunity Network