- Banking and non-banking
2 Business Situation
- Examiners found that one or more debt collectors claimed and collected from consumers, interest not authorized by the underlying contracts between the debt collectors and the creditors.
- Impact - Collection of an unauthorized debt by falsely representing the amounts due is a direct FDCPA violation prohibiting the use of any false, deceptive, or misleading representation or means in the collection of any debt
- Highlights the loans where amounts collected were more than the actual amount due or filters any exception being made on the account for collection of a higher or lesser amount than the actual amount due.
- Records are classified as ‘Compliant’ when the amount collected is the actual amount due and ‘Non-compliant’ when the amount collected is more than actual amount due.
5 Value Delivered
Initiating certain debt collection testing rules coupled with effective remediation activities helps:
- Significantly reduce the consumers risk of financial loss and/ or initiation of inadequate default activities.