An August decision by the U.S. Court of Appeals for the Seventh Circuit holding that an e-mail from a debt collector providing hyperlinks to disclosures required by the Fair Debt Collection Practices Act (FDCPA) actually violates that statute carries implications for the regulated community, which may have to modify its e-mail practices.
In a separate development, the Consumer Financial Protection Bureau has extended to Sept. 18 the public comment period on its proposed rulemaking implementing the FDCPA. The proposed rule, published for comment in May, would amend the part of the implementation that prescribes rules governing debt collection communications and disclosures. As proposed, hyperlinked e-mails would be allowed in certain circumstances.
