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ARTICLE · 12 JULY 2022

CFPB Targets Convenience Fees

Cooley LLP
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On June 29, 2022, the Consumer Financial Protection Bureau issued an advisory opinion declaring that the Fair Debt Collection Practices Act (FDCPA) prohibits debt collectors...

United StatesFinance and Banking
Katherine L. Halliday
Katherine L. Halliday
Katherine Brockway Katz
Katherine Brockway Katz
H. Joshua Kotin
H. Joshua Kotin
Michelle Rogers
Michelle Rogers
Christopher Walczyszyn
Christopher Walczyszyn
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On June 29, 2022, the Consumer Financial Protection Bureau issued an advisory opinion declaring that the Fair Debt Collection Practices Act (FDCPA) prohibits debt collectors from collecting "pay-to-pay" or convenience fees unless applicable law or the agreement creating the debt expressly authorizes the fee. According to the opinion, debt collectors also may be acting in violation of the FDCPA when using a third-party payment processor that charges such fees, if the processor remits to the collector any amount in connection with that fee. The CFPB considers convenience fees to include any fees incurred by consumers to make payments to a debt collector through a particular channel, such as by phone or online.

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