Do States Replace the CFPB? An Analysis in the Shifting Regulatory Authority in Consumer Finance

By Kelly Knepper-Stephens on October 10th, 2025 in Compliance

The blog title set in front of a map of the US.

After its creation the Consumer Financial Protection Bureau (CFPB) had a broad mandate covering nearly all consumer financial products. The CFPB wielded expansive rulemaking, supervision and enforcement powers. As noted in their Fiscal Year 2024 Financial Report, in 2024 alone, the CFPB conducted 26 public enforcement actions through settlement, litigation or default judgment. With the administration change, the CFPB has entered a deregulatory phase.

The new priorities represent a sharp contraction of their mission. In a memo to staff, the Bureau announced it will cut exams by half, refocus on the biggest banks, and pursue a narrower set of enforcement cases centered on clear, measurable fraud. They’ve taken a drastic step back, cutting staff, retracting years of guidance, and focusing on enforcement and some rulemaking.

The philosophical core of this shift is a policy the CFPB calls “respect for federalism.” This is an explicit directive to avoid duplicative work and let states take the lead. The internal memo to staff confirmed this is a strategic decision to shift resources away from tasks states can handle. We even see this logic in the Bureau’s justification to rescind 67 pieces of guidance, some that had provided clarity to the industry, in part due to the existing authority of state regulators. This shows a clear, deliberate handoff of regulatory responsibility.

It’s a mistake to view this as simple deregulation. In our dual-sovereignty system, a federal vacuum doesn’t lead to a void. It leads to a flurry of state-level activity. For a national company, this means replacing one predictable federal regulator with 50 unpredictable state ones.

And, not surprisingly, as a result, the states are picking up the baton and stepping up to fill the regulatory gaps. States are expanding their oversight and passing new legislation that is reshaping the compliance landscape for consumer finance and the debt collection industry. This has left many people asking the question, are states going to replace the CFPB? We’re here to help you find the answer.

How State Enforcement Works for Consumer Finance and the Debt Collection Industry

The states have the legal authority, institution structures and legislative will to fill the CFPB void. As states are taking over the reins as the main enforcement authority, their actions mainly take place at two different levels:

State Attorney Generals: They are the chief legal officers of their respective states and primary consumer protection enforcers. They wield broad authority on state Unfair Deceptive Abusive Acts and Practices statutes. They can investigate, subpoena, and sue for penalties and restitution.

State Financial Regulators: These are state-run agencies that oversee specific sectors of the financial industry. These agencies are usually responsible for licensing and supervising a wide range of non-bank entities, including mortgage lenders, debt collectors, and money transmitters. Some states are even hiring former CFPB employees to help get their regulations positioned to be more effective. New York, Pennsylvania and Maryland have actively recruited ex-federal workers to bolster their consumer protection efforts.

It’s also important to know that state agencies don’t operate in a silo. Many of them coordinate their efforts through interagency bodies such as the Conference of State Bank Supervisors (CSBS). By paying attention to these interagency bodies, businesses can get a better sense of debt collection compliance trends to account for in their operations.

What Are States Doing in This Enforcement Role?

Since the federal supervision activities are receding, states are taking the reins through their powers of supervision, enforcement and rulemaking. There has been a big surge in state-level legislative activity specifically aimed at areas where federal action has been slow. States are not just enforcing; they are actively writing the rules for the future:

The Bank Partnership Model (True Lending): One area that states are cracking down on is the “rent-a-bank model”. More states are trying to move forward with closing this banking loophole by forcing companies that use the true lending model to attain the same standard as traditional banks. A main motivation for this is to help protect consumers from deceptive lending and credit practices.

Regulation Around Fintech Products: States are moving faster than the federal government on creating rules around new financial products. As BNPL services continue to grow, New York has introduced new regulations including a new licensing system. Other states like Ohio have created “regulatory sandboxes” to see how new financial products could impact consumers before being rolled out statewide.

Medical Debt: As the CFPB’s medical debt rule was struck down in the courts as an unlawful extension of regulatory authority, several states introduced similar legislation aimed to prevent medical debt credit reporting, to create state-funded debt relief programs, and to expand patient relief programs. In several states, including California, Illinois, New York, Oregon and Washington the bills passed codifying in law restrictions on credit reporting medical debt.

Artificial Intelligence: In response to federal inaction, states have crafted their own unique legislative solutions to the challenges and opportunities presented by AI. Regulation of deepfake technology, particularly regarding non-consensual imagery, transparent disclosures when AI systems are used to interact with consumers, and formation of state-level task forces to study AI impacts and make policy recommendations. California, Colorado, Utah, Texas all have AI laws on the books with completely different requirements and definitions.

What Do These Changes Mean for Your Business and the Debt Collection Industry?

The idea that states are replacing the CFPB isn’t entirely accurate. States cannot replicate the CFPB’s most important function: creating a single, predictable set of rules for the entire country. The CFPB created a blanket of uniform rules which many states both formally and informally adopted. Today, the states are not creating a uniform floor but instead a patchwork of different requirements. This patchwork is more dynamic and, for industry, more complicated.

For any business operating in more than one state, the primary challenge is inconsistency. What is legal in Texas might be illegal in New York. This makes national product rollouts and standardized compliance programs incredibly difficult and expensive. Furthermore, enforcement is not uniform. A handful of states are very active, while many others lack the resources to bring major cases. Finally, state enforcement can be more political, with priorities changing every time a new attorney general is elected.

All of this together means that businesses are going to have to devote more resources into ensuring their collection efforts follow all the rules in the states in which they operate. This means actively tracking legislation, new regulations, and enforcement trends in every state where you do business. This can no longer be an afterthought; it must be a core compliance function. Conduct detailed, state-by-state risk assessments. Don’t assume a product that is compliant in one state is compliant everywhere. Pay extremely close attention to the bellwether states—California, New York, Pennsylvania, and Massachusetts. What happens there often doesn’t stay there; it becomes the template for other states to follow.

Following the activities of the state AGs, who are the source of the broad UDAAP actions and novel legal theories, is a must. Along with the specialized financial regulators, who control your licenses and conduct the day-to-day examinations. These are two different sources of risk that require distinct monitoring strategies.

These changes demand a more sophisticated and adaptable compliance management system. Your systems must be flexible enough to handle different disclosure requirements, different collection rules, different UDAAPs interpretations, often on a state-by-state basis. Investing in this adaptability is the key to managing risk in this fragmented landscape.

Small compliance departments face an immense, constantly evolving task and often don’t have the capability to scale their efforts to match the sheer number of new regulations that can emerge. Companies like TrueAccord can help your business leverage digital communications that are compliant at the federal and state levels.

Compliantly Scaling Your Debt Collection Efforts is Easy with TrueAccord

The regulatory landscape around financial services and debt collection will continue to evolve. While states aren’t a complete replacement for the CFPB, new state-level regulations will continue to be passed and make it more challenging for your business to stay compliant.

One of the best ways to keep up with this dynamic landscape is to partner with TrueAccord for your debt collection needs. TrueAccord combines dedicated legal experts with code-based compliance to ensure debt collection efforts are by the book. Contact our team today to learn more about how your businesses can compliantly scale your collection efforts.

How Student Loan Debt is Impacting the Debt Collection Industry

By Matt Kulik on August 8th, 2025 in Industry Insights, Customer Experience, Machine Learning

The blog title set in front of a piggy bank wearing a graduation cap.

The path to getting a higher education is a courageous decision that millions of Americans start each year when attending college. It sets the foundation for countless careers and drives personal growth that lasts a lifetime. However, education is expensive and paying back the loans can be challenging—an estimated 5.8 million student loan borrowers have delinquent accounts.

This number could get even higher with student loan forgiveness ending, interest on the debt resuming and shifts repayment options. Student loans and debt collection servicing have always shared a close relationship. And the current changes to the federal student loan system is primed to send shockwaves through debt collection services across the nation.

Learn how student loans have changed in 2025 and trends your business needs to look out for as the situation continues to evolve.

How Student Loans Have Changes in 2025

Before we dive into the implications for the debt collection industry, it’s important to understand some of the key changes recently made to federal student loans. The current administration signed into law the “One Big Beautiful Bill Act” on July 4th, 2025. This legislation overhauled the student loan system:

Student Loan Forgiveness Paused: Borrowers on SAVE plans are seeing the end of payment forgiveness. Right now, payments are required and accruing interest on loans restarted on August 1st, 2025.

Creation of Repayment Assistance Plan (RAP): RAP is an income-based plan for new borrowers that requires a minimum payment regardless of a person’s income level. This plan will only be approved for cancellation after 30 years of qualifying payments.

Student Loan Payments Likely to Increase: With all the changes happening to the system, it’s very likely that borrowers will see their student loan payments increase. It’s estimated some Americans will see their student loans cost potentially a few thousand dollars more each year.

Student Loans and Their Impact on Debt Collection

One of the biggest and most immediate effects that student loans will have on debt collection solutions is a surge of collection activity. With loan forgiveness paused, the millions of delinquent accounts are going to be subject to collection efforts. To start, the federal government is putting increased focus on accounts that are 60 days or more delinquent.

This means that standard debt collection communications channels like phone calls and physical mail are going to be much more crowded for the foreseeable future. It’s also likely that some customers your business talks to have this type of financial obligation. That means no matter what debt type you’re collecting, there is more competition to get their attention through non-digital channels and less funds available to repay debts.

We Could See An Increase in Involuntary Collection Tools

When a consumer defaults on their student loan debt, the federal government has strong tools to help them collect payments. After 270 days pass without a payment being made, the government can garish up to 15% of the borrower’s paycheck. Any federal tax refunds can also be withheld and applied to the loan.

Any student loan accounts that are in delinquency or have defaulted can also be reported to national credit bureaus, causing damage to the borrower’s credit score. Consumers who are going through this process may be less likely to make payments on other debts while they try to keep up with student loans. The common thread is that more student loan borrowers could have reduced disposable income once all the changes take effect.

New Student Loan Rules Could Lower Credit Scores

Experts agree that the new student loan rules have a strong possibility of lowering credit scores for existing borrowers. Since the payment forgiveness that started shortly before COVID is ending, borrowers will likely need time to make payments as other costly necessities (like the rise of grocery costs) take their attention.

It’s possible that this will have widespread effects on consumer credit scores, making it more difficult for these borrowers to participate in the financial system. Specifically for student loans, a lower credit score makes it harder for borrowers to consolidate the debt at an affordable interest rate.

A lower credit score also makes it more difficult to access new lines of credit, a common tactic consumers use to pay off debt. Borrowers with a lower credit score will get higher interest rates on new loans, making it more expensive to get loans and more likely that payments made on debts will be in smaller amounts. To help navigate this challenge, debt collection services that offer consumers more payment options could have greater success.

Increase Your Collections Performance with an Industry Leading Platform

Student loan debt is primed to have a lasting impact on debt collection solutions. If you want to leverage AI that adapts to these situational challenges to collect more from happier people, TrueAccord is here to help.

If you want to empower your debt collection solutions with machine learning and a consumer-friendly digital experience, contact our sales team today.

Q2 Industry Insights: Reconciling consumer, economic indicators and embracing AI

By Mark Ravanesi on July 29th, 2025 in Industry Insights, Customer Experience, Machine Learning

The blog title with an illustration of a lightbulb.

Despite economic uncertainty, Americans continue to spend, albeit what they’re spending on has shifted. After two consecutive months of reduced spending, consumers came back in June with purchasing focused heavily on necessities like clothing and personal care, rather than electronics or appliances. Discretionary spending also stayed strong on restaurants and bars, indicating that while consumers are feeling some amount of pressure from the economy, it hasn’t really hit their wallets just yet. But economists and key indicators are foretelling more financial challenges ahead, so consumer sentiment may not be keeping up with reality.

The debt collection industry is navigating a period of transformation via a combination of regulatory shifts, technological advancements and evolving economic pressures. Key developments continue to reshape collection strategies, compliance requirements and the tools used to recover outstanding debts. As you protect your bottom line in a rapidly evolving consumer financial landscape, let’s look at what you should consider as it relates to debt collection with an eye toward the second half of 2025.

Key Economic Indicators

After several months of speculation and fluctuation, inflation is starting to heat back up, potentially showing the first impacts of tariffs and signaling what’s ahead. Consumer prices rose 0.3% in June after rising 0.1% in May, pushing the annual CPI inflation rate higher to 2.7%, the highest since February. The increase was driven by higher gas prices and a broad assortment of goods showing the effects of businesses sharing higher import costs with consumers.

On the jobs front, the economy added 110,000 jobs in June. Looking at the number of jobs added through the first part of the year shows an average of 124,000 jobs per month, which is significantly lower than last year’s monthly average of 168,000. With layoff activity relatively low and wage growth remaining decent, economic uncertainty has slowed the pace of hiring and created a somewhat stagnant employment market.

The Federal Open Market Committee held rates steady at 4.25-4.50% at their meeting in mid-June, and Wall Street economists are predicting the central bank to continue their wait-and-see approach at their next meeting in July given June’s reported CPI and expected PCE inflation increases. Bets are now on a September rate cut if the inflation threat cools and the jobs market weakens more noticeably.

The Federal Reserve Bank of New York’s latest Quarterly Report on Household Debt and Credit for Q1 2025 showed that total household debt in the US reached $18.20 trillion, a $167 billion or 0.97% increase from the prior quarter. This growth was primarily driven by increases in student loan and mortgage balances, while credit card and auto loan balances decreased. The report showed delinquency rates rising, with 4.3% of outstanding debt in some stage of delinquency, the highest level since the beginning of 2020.

Mortgage loans experienced a significant rise in early and mid-stage delinquencies across all credit categories in May. Mortgage delinquencies increased to 1.03% from 0.92% the previous month, suggesting that the housing market might be showing initial indicators of financial strain among homeowners.

What’s Impacting Consumer Finances?

Just as more student loan delinquencies are reported and sent to collections, borrowers who had previously been granted an interest-free forbearance period under the Saving on a Valuable Education (SAVE) Plan will lose those benefits. On August 1, the administration will resume interest charges on the accounts of around 8 million borrowers as the SAVE program and several other income-driven payment options end. Overall, the change will see borrowers being charged more than $27 billion in interest over the next 12 months, which will have wide repercussions on students and families.

And in a reversal of a move by the Consumer Financial Protection Bureau (CFPB) earlier this year, a federal judge recently blocked a rule that would have removed unpaid medical debt from the credit reports of about 15 million consumers who carry a total of roughly $49 billion in medical debt. This financial burden could influence creditworthiness and access to loans for many.

What’s Impacting the Debt Collection Industry?

On the federal level, the CFPB has announced a new set of supervision and enforcement priorities for 2025. The bureau intends to reduce the number of its supervisory exams, focusing instead on cases of tangible consumer harm and actual fraud. While this may mean fewer routine audits for collection agencies, it signals more intense scrutiny on practices that directly and negatively impact consumers, with a continued focus on areas including mortgages, credit reporting, and FCRA and FDCPA violations.

In June, the CFPB also published a policy statement in the Federal Register outlining its approach to addressing criminally liable regulatory offenses under statutes including the Consumer Financial Protection Act and Truth in Lending Act, among others.

In efforts to enhance efficiency, the debt collection industry is rapidly embracing new technologies, and artificial intelligence (AI) and digital communication platforms are at the forefront of this technological wave. AI is being leveraged more widely to personalize consumer engagement, predict payment likelihood, and optimize collection strategies. Meanwhile, digital channels like Rich Communication Services (RCS) are gaining traction as innovative methods for consumer contact, offering more interactive and self-service options.

However, the use of technology and collection tactics remains under the watchful eye of regulators. In a significant enforcement action in June 2025, the Federal Trade Commission (FTC) secured a permanent ban against a debt collection operation found to be using deceptive and harassing methods to collect on “phantom debts.” This action underscores the agency’s ongoing commitment to cracking down on illegal collection practices and serves as a reminder to the industry of the severe consequences of non-compliance.

How are consumers feeling about their financial outlook?

In analyzing consumer sentiment, it’s important to note that the following surveys relay responses may have been taken before the latest inflation figures were released, so there may be an incongruity in reporting.

The Fed’s June Survey of Consumer Expectations showed that households’ inflation expectations decreased at the short-term and remained unchanged at the medium- and longer-term periods. Unemployment job loss and household income growth expectations improved while spending growth expectations slightly declined. In general, households were more optimistic about their year-ahead financial outlook.

The latest University of Michigan consumer sentiment survey, reporting from mid-way through July, showed that Consumer sentiment ticked up about one index point to 61.8 from June, reaching its highest value in five months, but still 16% below December 2024 and its historical average. Expected personal finances fell back about 4%, with the report noting that consumers are unlikely to regain their economic confidence until they feel assured that inflation is unlikely to rise.

The Conference Board’s Consumer Confidence Index deteriorated by 5.4 points in June, falling to 93.0 from 98.4 in May. The report showed less positivity about current business conditions and job availability, as well as more pessimism about business conditions, job availability and income prospects over the next six months.

What Does This Mean for Debt Collection?

The debt collection industry in mid-2025 is at a pivotal juncture, tasked with balancing the adoption of powerful new technologies and navigating a challenging economic environment while adhering to an evolving regulatory framework. The ability to adapt to these concurrent trends will mean success for businesses in this sector. For lenders and collectors, here are a few things to keep in mind:

Consumers expect more in debt collection. Gone are the days of debt collection letters or calls from unknown numbers eliciting a productive response. Now, consumers want empathy, understanding and convenience in their financial matters. Keeping up with consumer expectations can mean the difference between collecting debt and not.

Self-service is one of those key expectations. Convenience by way of self-serving is a win-win for your business and consumers. Offering a comprehensive self-serve portal means consumers can engage whenever they want (even outside traditional FDCPA-regulated hours) and reduces resources needed to manage accounts and process payments.

Ready or not, AI is here. Technology is already transforming debt collection by changing the way lenders and collectors engage with consumers, and if you’re not getting on board, you’ll find your business soon left behind. The time to thoughtfully adopt AI is now. Not sure where to start? Here are the must-know tech terms to get you going.

SOURCES:

Associated Press – U.S. retail sales
U.S. Bureau of Labor Statistics – June CPI
Wall Street Journal – Jobs report
Marketwatch – FOMC rate cuts
Federal Reserve Bank of New York – Q1 Report on Household Debt and Credit
VantageScore – Mortgage delinquencies
Newsweek – Student loans / SAVE cuts
CBS News – Medical debt ruling
Consumer Financial Services Law Monitor – CFPB enforcement priorities
Federal Register – CFPB policy statement
Customer Experience Dive – RCS
FTC – Phantom debts ruling
Federal Reserve Bank of New York – June Consumer Expectations Survey
University of Michigan – July Consumer Sentiment Survey
The Conference Board – June Consumer Confidence Survey

One Size Doesn’t Fit All in Debt Collection

By Matt Kulik on July 25th, 2025 in Customer Experience, Machine Learning, Product and Technology

The blog title with a picture of a cat sitting in a box that's too small.

What if there was an ice cream shop that only sold vanilla? Just one flavor, offered in one size without any extra options. How much business do you think this shop would get? We know that it’s probably not a profitable business model because it contradicts one of the most important trends seen across countless industries – honoring customer preferences.

In the debt collection industry, there’s a lot of businesses out there practicing the “single flavor” or one-size-fits-all approach. Customers only get sent notices through one or two communication channels and have a single type of payment option.

Debt collection solutions shouldn’t be one-size-fits-all. If you’re interested in learning how to improve the debt collection customer experience, it starts with finding ways to accommodate more preferences.

Why Isn’t Personalization More Common in Debt Collection Solutions?

It’s no surprise that consumers have personal preferences that impact their engagement with businesses. One of the most important preferences is how they want to be contacted. While phone calls used to be the go-to method for debt collection, in today’s digital world any unknown number is usually automatically labeled as spam in a person’s mind.

In the debt collection industry today, there’s no shortage of communication channels. So why do so many debt collection companies go for a one-size-fits-all approach through a more outdated method like phone calls or physical mail? There’s a few challenges that can help explain it:

Content Library Creation: The process of building and managing an extensive digital content library for debt collection isn’t easy, especially given compliance requirements for all the different channels like email, text, self-serve portals. This process requires writers and content experts who understand debt collection solutions and the pain points consumers experience.

Lack of Resources: Many debt collection companies lack the resources to build out the strategy and operations for multiple or digital channels.

Not Leveraging AI: Without AI and machine learning, it’s much more challenging to figure out what type of content and channel resonates with each individual and implement customized communications at scale

Just like the scenario we listed above, only offering “one flavor” usually leads to less effective debt collection solutions, lower performance and unsatisfied consumers.

Improve the Debt Collection Customer Experience with Personalization

The main reason to take a personalized approach to debt collection solutions is to help more consumers repay debts and reach greater financial health. To do that, consumers need to engage with debt collection messages. For starters, 46% of consumers expect companies to reach out to their preferred channels. When this happens, companies see a 10% increase in payments from delinquent customers. But preferred channels aren’t the same for everyone.

With financial matters (including debt collection and bill notifications), people increasingly prefer digital communication channels. In fact, 59.5% of consumers list email as their first contact choice for communication from a company. When you meet someone’s expectations, payment reminders are more likely to be noticed and acted on. While honoring a consumer’s preferred channel is important, it’s not the only customization that can make an impact.

Customizing Content Gets Results

It’s common for debt collection companies to have a few sets of communication templates, but the content itself doesn’t change much. But with an eye toward data-driven changes and testing, there’s always an opportunity to adjust content to catch attention and better engage consumers.

For example, TrueAccord had a client that wanted to improve the performance of debt notification emails. The TrueAccord team created emails that included animated GIFs, an idea supported by machine learning data. This strategy led to a 6% increase in click rates and a happy client that became excited about future tests.

The best debt collection solutions treat content as a living strategy. That means updating content templates on a regular basis and testing new ideas to keep up with shifts in customer preferences. One crucial element that makes this possible are AI tools that measure effectiveness and ensure the content is compliant.

Personalization is Better with an Omnichannel Approach

An omnichannel approach to debt collection solutions means leveraging a combination of communication channels for consumers to engage with. Every channel like email, text, self-serve portals and more are integrated into a consumer-centric approach. These channels work together to uncover the best option for each individual.

Beyond simply adding digital channels, companies need to adopt a customized omnichannel debt collection approach to engage consumers through preferred channels. At TrueAccord, this is achieved through a patented machine learning engine called Heartbeat. Consumer engagement with Heartbeat is automated and optimized by data-driven algorithms that decide what timing, message and channel will be most effective for each individual person.

By finding the right timing, message and channel, your debt collection solutions won’t just help more consumers engage in debt repayment, but you’ll recoup more in a cost-effective way.

See What TrueAccord’s Debt Collection Technology Can Do

Does your business want to collect more from happier customers? At TrueAccord, we use AI tools to offer a personalized and self-serve experience that honors consumer preferences. To learn more about our industry-leading results, connect with our team today!

Millions of Student Loans in Debt Collection, How Did We Get Here?

By Noelle Robillard on May 15th, 2025 in Industry Insights

You’ve seen the headlines—the federal government last week resumed collecting defaulted student loan payments from millions of people for the first time since the start of the pandemic. And how—debt collection will be through a Treasury Department program that withholds payments through tax refunds, wages and government benefits. This will undoubtedly have negative effects on credit scores and the resulting loss of access to funding going forward for many Americans.

How did we get to this point where so many people with student loans are unable to make payments on them? Taking a look back at the financial activity of those who deferred student loan payments in the first place gives us a good jumping off point, and combined with the challenging economic landscape over the past several years we can begin to understand the precarious financial situation unfolding.

Student Loan Holders Took on More Debt During the Pandemic

Based on data analysis we reported on in “Consumer Finances, Student Loans and Debt Repayment in 2023”, the trend for student loan holders who deferred their payments from 2020-2022 was to take on more debt. Data showed that the total average debt of a consumer with student loans increased 14.6% from 2020 to 2022, while that of consumers without student loans decreased 4.8%.

In 2022, student loan holders increased their average number of open trade lines by 10.3% from 2020, while open trade lines decreased by 7.7% for non-student loan holders. Breaking it down, those with student loans added credit cards (up 8%), personal loans (up 4%) and personal installment loans (up 5%) to their debt balances, with the average total balance of other loans more than doubling from 2020-2022, from $2,078 to $4,747, a 128% increase.

Economic Stressors Have Persisted, Are Likely to Continue

While inflation has cooled significantly compared to the highs of 2021 and 2022, prices remain elevated and interest rates haven’t returned to pre-pandemic levels. Uncoincidentally, household debt and credit card balances have been on a steady upward climb for the past few years, suggesting that rather than catching up with their finances, many Americans have continued to find new sources of funds to support their lives.

Americans’ total credit card balance was $1.2 trillion as of Q4 2024, marking the 10th time in 11 quarters where credit card debt increased or stayed the same. In a bigger picture view, credit card balances have risen by $441 billion since Q1 2021—adding up to a 57% increase in less than four years. Given the still-high interest rates, stubborn inflation (that may or may not go back up due to tariffs) and other turbulent economic factors, these balances are likely to keep climbing.

A Perfect Storm of Financial Challenges for Student Loan Holders

While deferred payments on student loans granted a temporary reprieve for borrowers, the new debt accrued effectively negated the gains of deferral, leaving many student loan holders with monthly debt obligations that were only manageable without having to pay back student loans. The CFPB reported that as of September 2022, 46% of student loan borrowers had scheduled monthly payments for all credit products (excluding student loans and mortgages) that increased 10% or more relative to the start of the pandemic.

Monthly financial obligations directly impact a consumer’s overall financial flexibility, and maxing out budgets to keep up with the economy puts people in a precarious situation when demands on finances change. That’s what we’re seeing now—consumers put student loans on the backburner and weren’t able to financially prepare for when they would come due again.

What Happens Next?

The outlook isn’t great: financially at-risk consumers with student loans will either go into collections for their student loans or will start missing payments on other loans in an attempt to pay back student loan debt. When there is only so much in the bank to work with and the cost of accessing new money is high, consumers will have to prioritize financial obligations and inevitably won’t be able to cover them all.

As we’ve learned from working with more than 40 million consumers in debt, empathy goes a long way, and understanding your customers’ financial situation is the first step to effectively engaging them in debt collection. For creditors and debt collectors looking to engage consumers in debt collection right now, it’s important to have a comprehensive, omnichannel communication strategy and be ready to meet the customer when and where they are ready to prioritize your account. This means don’t limit communication channels and do offer flexible options for repayment that consumers can explore, evaluate and select on their own time.

To engage your customers earlier in delinquency before charge off, consider leveraging consumer-preferred digital channels and AI-enabled decisioning for optimal results. Implementing a SaaS tool to automate digital communications will help you keep up with rising delinquencies while keeping your costs low.

For more data analysis insights on this topic and how to improve engagement with borrowers with student loans, download and read the full report “Consumer Finances, Student Loans and Debt Repayment in 2023”.

Q1 Industry Insights: Started Strong, But “Considerable Turbulence” Leaves Consumers on Edge

By Mark Ravanesi on April 28th, 2025 in Industry Insights

What do canceled hair appointments and increased lipstick and beer sales have in common? These untraditional indicators, among other discretionary expenditure trends, often show consumer sentiments around finances well before a recession hits. Coming out of 2024, the average U.S. household owed $11,303 on credit cards, and while credit card charge-off rates and delinquencies both declined slightly, experts are not declaring a definitive turnaround given the ongoing economic uncertainties and high balances. Consumers today are confronted with new developments regularly, leading to “considerable turbulence” in the words of JPMorgan Chase CEO Jamie Dimon, and without much guidance on what the implications are for their personal financial outlook, which understandably affects their spending and budget considerations.

The main challenge in engaging with consumers in debt in today’s economic climate is how to offer them an affordable way forward. Other challenges for businesses’ debt collection operations come in the forms of regulatory changes impacting innovation and uncertainty about staying in compliance.

As you try to keep up with your bottom line in a rapidly evolving consumer financial landscape, let’s look at what you should consider as it relates to debt collection moving forward in 2025.

What’s Impacting Consumers?

It’s important to note that this report is from data covering a period of time before the majority of new tariffs went into effect, and everyone from Wall Street to consumers are waiting to see what happens next. Against a backdrop of an erratic market and general unease about the future of the U.S. economy, inflation reports offered a bright spot showing cooling in March to close out Q1. The consumer price index (CPI), excluding volatile food and energy costs, increased 0.1% from February, climbing 2.4% from a year earlier—the least in nine months and lower than expected. The overall CPI declined 0.1% from a month earlier, the first decrease in nearly five years, reflecting a decline in energy costs, used vehicles, hotel visits, car insurance and airfares.

The overall jobs numbers from March signaled a solid labor market, with employers adding 228,000 jobs and the unemployment rate changing little to 4.2%. Job gains showed up

in health care, social assistance, transportation and warehousing, along with retail trade, which reflected the return of workers from a strike, while federal government employment declined as a result of wide-reaching layoffs.

The Federal Reserve (Fed) held rates steady at 4.25-4.50% in March. In its statement following the March meeting, the Fed stated that “uncertainty around the economic outlook has increased.” As a result, the Fed lowered economic growth expectations to 1.7% gross domestic product (GDP) growth in 2025, down from a 2.1% estimate, while upping the projected core PCE inflation rate to 2.8% from 2.5%. The next meeting is on May 6 and while many still expect two rate cuts this year, the outcome will reflect the bank’s outlook given the new landscape of tariffs and their anticipated impact on inflation.

In February, the Fed released its Quarterly Report on Household Debt and Credit for Q4 2024, which showed total household debt increased by $93 billion in Q4, to $18.04 trillion. The report also showed that people are having more trouble paying off that debt, with credit card balances increasing by $45 billion to $1.21 trillion and auto loan balances increased by $11 billion to $1.66 trillion. Delinquency rates ticked up 0.1% from the previous quarter, with 3.6% of outstanding debt now in some stage of delinquency. Transition into serious delinquency, or 90+ days past due (DPD), also increased for auto loans, credit cards and HELOC balances.

Experian’s Ascend Market Insights from February 2025 data showed that overall delinquent balances (30+ DPD) increased by 16.67%, driven by a 537.4% increase in delinquent student loan balances, a 16.28% increase for first mortgages and a 4% increase for bankcard balances. The huge surge in delinquent student loans is due to an increase in the volume of 90 DPD data furnishers have started to report after the pause on student loan payments ended.

By the end of February, nearly 8 million people with student loans had missed resumed payments and were met with plunging credit scores. As it stands, 1 in 5 people who are supposed to be making payments on their federal student loans are more than 90 DPD, nearly double the percentage of delinquent borrowers since the pandemic hit and the government paused payments, with reasons for delinquency ranging from inability to pay and difficulties working with servicers to missed communications that never reached the recipient.

The CFPB, Regulations and Compliance are Evolving

While the Consumer Financial Protection Bureau’s (CFPB) normal activity has been disrupted due to changes in direction from the administration, it did release a report looking at national rental payment data from September 2021 to November 2024 showing that the percentage of renters who paid late fees in the last year reached 23% in February 2023. While the rate had declined to slightly less than 14% in November 2024, the CFPB’s analysis found that the median outstanding rental balance rose 60% between September 2021 and November 2024, suggesting increased financial distress among affected households.

Meanwhile, the Federal Communications Commission (FCC) is seeking public input on identifying FCC rules for the purpose of alleviating unnecessary regulatory burdens. In a public notice released March 12, 2025, the FCC announced the Commission is seeking comments on deregulatory initiatives to identify and eliminate those that are unnecessary in light of current circumstances. The FCC notice stated: “in addition to imposing unnecessary burdens, unnecessary rules may stand in the way of deployment, expansion, competition, and technological innovation.”

In the meantime, two FCC Orders about the Telephone Consumer Protection Act (TCPA), which applies only to calls and texts made by an automated telephone dialing system (ATDS) and prerecorded or automated voice calls (aka robocalls or robotexts) come into effect. First, a 2024 Order released last February impacting revocation of consent to receive autodialed calls and texts and prerecorded or artificial voice calls. The 2024 Order conflicts with the CFPB’s Regulation F Debt Collection Rule about the scope of an opt-out. Second, is a 2025 Order released this past February aiming to strengthen call blocking of illegal calls, which may result in the blocking of lawful debt collection calls and texts.

Debt collectors and other companies impacted by these two orders may want to submit comments to the FCC identifying the particularly burdensome aspects that could be revisited and slightly revised to be consistent with consumer preference, consistent with other laws and regulations (like Regulation F), and less burdensome on companies.

Eyes will continue to be on the developments with the ever-evolving regulatory landscape and what happens with the CFPB, which will impact how businesses both comply with regulations and innovate through technology in consumer financial services.

Consumer Sentiment

The Fed’s March Survey of Consumer Expectations showed that inflation expectations increased by 0.5% to 3.6% at the one-year-ahead horizon while consumers’ expectations about their households’ financial situations deteriorated with the share of households expecting a worse financial situation one year from now rising to 30%, the highest level since October 2023. The report also showed Unemployment, job loss, earnings growth and household income growth expectations also deteriorated.

The latest University of Michigan consumer sentiment survey showed that sentiment fell to 50.8, down from 57.0 in March. The drop, a 10.9% monthly change and 34.2% lower than a year ago, was the lowest reading since June 2022 and the second lowest in the survey’s history since 1952. Respondents’ expectation for inflation a year from now jumped to 6.7%, the highest level since 1981. The current economic conditions index and expectations measure dropped by 11.4% and 10.3% from March respectively.

Similarly, the Conference Board’s Consumer Confidence Index in March fell by 7.2 points to 92.9. The Present Situation Index, based on consumers’ assessment of current business and labor market conditions, also decreased 3.6 points to 134.5 while the Expectations Index based on consumers’ short-term outlook for income, business and labor market conditions fell 9.6 points to 65.2, the lowest level in 12 years and well below the threshold of 80 that usually signals a recession ahead.

What Does This Mean for Debt Collection?

All of the economic indicators and pessimistic consumer outlook, especially given stock market turbulence that impacts many Americans’ retirement savings, makes it likely that consumers across all income brackets will pull back on discretionary spending. And for those already financially stressed, the added burden of increased inflation due to tariffs could make it harder for budgets to meet debt obligations. For lenders and collectors, here are some recommendations for your debt collection strategy in 2025:

Ensure Your Messages Are Getting Through. If you’re calling someone who prefers to receive information by email, they likely won’t answer and get your message. Similarly, if you’re using digital channels and your email gets caught in a spam folder, your message won’t make it to the intended recipient. Best practices for email delivery and deliverability are just as important as using the right channel. Ensure your collection partners who claim to engage consumers via email can back it up with the metrics to prove that their messages actually make it through.

Do More With Less. Technology exists today that can create efficiencies across many aspects of debt collection operations, which means increasing account volume doesn’t have to equal higher costs. Look for ways you and your collection partners can leverage new tech to streamline operations and you can reap the benefits of improved operational efficiency, compliance efforts and consumer experience.

Get Your Lawyer on Speed Dial. Or ensure your debt collection partner is keeping tabs on the rapidly evolving regulatory and compliance landscape to inform their practices. There’s a lot going on, quickly, and if you miss something the repercussions of noncompliance could cost you financially or reputationally.

SOURCES:

WalletHub – Credit Card Debt
InsideArm – Credit Card Charge-Offs and Delinquencies
Reuters – J.P. Morgan CEO Notes “Considerable Turbulence”
Bureau of Labor Statistics – March Jobs Report
Federal Reserve – FOMC Statement
Federal Reserve – Household Debt and Credit Report
Washington Post – Student Loans
CFPB – Challenges for Households that Rent
FCC – 2024 Order
FCC – 2025 Order
Federal Reserve – March Consumer Expectations Survey
University of Michigan – Consumer Sentiment Survey
The Conference Board – Consumer Confidence Index

Q4 Industry Insights: Looking Good on Paper, Feeling Bad in Wallets, Everyone’s Uncertain on Financial Outlook

By Mark Ravanesi on January 21st, 2025 in Industry Insights, Compliance

Looking at key economic indicators—GDP growth, consumer spending, softening inflation and a healthy job market—it would be easy to deduce that consumers in America are faring well. But digging deeper reveals unwieldy debt, expected rises in charge-offs and uncertainty around future economic conditions, painting a less rosy picture of the financial situation.

Consumers certainly faced challenging economic conditions in 2024, but despite record-high credit card balances and delinquency rates, Americans continued spending, accumulating even more debt this holiday season. Data shows that more than a third of shoppers took on additional debt for the holidays, borrowing $1,181 on average, and that 47% of consumers still carried debt from the 2023 holiday season. With inflation proving more sticky than policymakers had hoped and uncertainty around how the new administration’s policies might affect it, it may take longer for people to see lower interest rates on their mortgages, car loans and credit card balances, which could prove challenging to household budgets.

The good news for lenders and debt collectors is that a reported 72% of consumers have a New Year’s resolution to pay off debt in 2025. The challenges will be effectively engaging consumers who want to repay and accommodating their strained budgets. We are entering a year of unknowns across the board, from potential regulatory changes to economic fluctuations to varying consumer sentiments, and there’s a lot to consider as it relates to debt collection in 2025.

What’s Impacting Consumers?

While inflation isn’t cooling dramatically, it also isn’t showing signs of speeding back up. December’s inflation reading didn’t bring any big surprises to close out 2024—the consumer price index (CPI) increased 0.4% on the month, putting the 12-month inflation rate in line with forecasts at 2.9%. The core CPI annual rate, which discludes volatile food and fuel prices and is a key factor in policy decisions, notched down to 3.2% from the month before, slightly better than forecasted.

Despite the nagging inflation and still-elevated borrowing rates, the job market remains resilient, with employers adding 256,000 jobs in December, nearly 100,000 more than economists expected. The unemployment rate in December ticked down to 4.1%, lower than the forecasted steady rate.

The Federal Reserve started cutting rates in September 2024 and lowered its benchmark for a third straight month in December based on signs that the economy was slowing down. But the healthy December jobs report combined with lingering inflation supports the Fed’s intention to move forward with a slower pace of rate cuts this year—it is now penciling in only two quarter-point rate cuts in 2025, down from the four it forecasted in September.

In November, the Fed released its Quarterly Report on Household Debt and Credit for Q3, which showed total household debt increased by $147 billion (0.8%) in Q3 2024, to $17.94 trillion. The report also showed that credit card balances increased by $24 billion to $1.17 trillion, with the average U.S. household owing $10,563 on credit cards going into the Q4 holiday shopping season. According to Experian’s Ascend Market Insights, at the end of November, 5% of consumers had total balances over their limits and 11% of consumers had a high utilization of 81-100%.

Experian’s Ascend Market Insights from November also showed overall delinquent balances (30+ DPD) decreased by 3.78% while up on unit basis by 1.61%. This net was driven by decreases in delinquent first mortgage and unsecured personal loan balances, which were offset by increases in delinquent bankcard balances and on a dollar basis in delinquent second mortgages.

Meanwhile, millions of Americans may see significant changes to their credit reports in the coming months if they have either unpaid medical bills or student loans, but the effects of each are opposite.

Since March 2020, delinquent student loan borrowers have been exempt from credit reporting consequences, but the required payments resumed in October 2024. As a result, an estimated 7 million borrowers who have fallen behind on their federal student loan payments or remain in default will start seeing negative credit reporting in the coming months if they don’t resume payments.

Conversely, for the roughly 15 million Americans with unpaid medical bills, a new rule from the Consumer Financial Protection Bureau (CFPB) will ban and remove at least $49 billion in medical debt from consumer credit reports and prohibit lenders from using medical information in their lending decisions, providing a boost to credit scores and financial access.

CFPB Looks at Medical Debt, Student Loans and So Much Data

Medical debt wasn’t the only focus for the Consumer Financial Protection Bureau in Q4. In addition to specific actions targeting offenders in the consumer financial services industry, the CFPB announced myriad other topics of interest to close out 2024 with a sharp focus on protecting consumers and their data.

At the end of October, the CFPB finalized a personal financial data rights rule that requires financial institutions, credit card issuers and other financial providers to unlock an individual’s personal financial data and transfer it to another provider at the consumer’s request for free, making it easier to switch to providers with superior rates and services. The rule will help lower prices on loans and improve customer service across payments, credit and banking markets by fueling competition and consumer choice.

In November, the CFPB issued a report detailing gaps in consumer protections in state data privacy laws, which pose risks for consumers as companies increasingly build business models to make money from personal financial data. The report found that existing federal privacy protections for financial information have limitations and may not protect consumers from companies’ new methods of collecting and monetizing data, and while 18 states have new state laws providing consumer privacy rights, all of them exempt financial institutions, financial data, or both if they are already subject to the federal Gramm-Leach-Bliley Act (GLBA) and the Fair Credit Reporting Act (FCRA).

Then, the Bureau finalized a rule on federal oversight of digital payment apps to protect personal data, reduce fraud and stop illegal debanking. The new rule brings the same supervision to Big Tech and other widely used digital payment apps handling over 50 million transactions annually that large banks, credit unions and other financial institutions already face.

As 28 million federal student loan borrowers returned to repayment, the CFPB issued a report uncovering illegal practices across student loan refinancing, servicing and debt collection, identifying instances of companies engaging in illegal practices that misled student borrowers about their protections or denied borrowers their rightful benefits. This followed the release of their annual report of the Student Loan Ombudsman, highlighting the severe difficulties reported by student borrowers due to persistent loan servicing failures and program disruptions.

Uncertainty in Consumer Sentiment

The Fed’s Survey of Consumer Expectations from December showed that inflation expectations were unchanged at 3.0% for this year, increased to 3.0% from 2.6% at the three-year horizon, and declined to 2.7% from 2.9% at the five-year horizon. Reported perceptions of credit access compared to a year ago declined as did expectations about credit access a year from now. Additionally, the average perceived probability of missing a minimum debt payment over the next three months increased to 14.2% from 13.2% and was broad-based across income and education groups.

The November PYMNTS Intelligence “New Reality Check: The Paycheck-to-Paycheck Report” found that from September to October 2024, the share of consumers living paycheck to paycheck overall rose slightly from 66% to 67%. Surveyed cardholders said their outstanding credit balance is either holding constant or increasing—25% said their outstanding balance increased over the last year, while 55% said it stayed about the same. Moreover, many consumers, and especially those having trouble paying their monthly bills, report maxing out their cards regularly and using installment plans to cover basic necessities.

According to NerdWallet’s 2024 American Household Credit Card Debt Study, more than 1 in 5 Americans who currently have revolving credit card debt (22%) say they generally only make the minimum payment on their credit cards each month. And with credit card rates averaging 20%, interest costs could almost triple the average debt for those making minimum payments after factoring in interest expenses.

The University of Michigan’s index of consumer sentiment dropped to 73.2 at the start of January 2025 from 74.0 in December after views of the economy weakened on expectations of higher inflation in light of the new administration’s proposed tax cuts and new import tariffs. Unlike some of the polarization of recent months, which had seen more positive responses among Republicans than Democrats, January’s deterioration in economic expectations was seen across political affiliations. While consumers’ views of their personal finances improved about 5%, their economic outlook fell back 7% for the short run and 5% for the long run, with year-ahead inflation expectations jumping to 3.3%, up from 2.8% in December and the highest since May last year.

What Does This Mean for Debt Collection?

Over the next 12 months, debt collection companies expect an increase in account volume but a potential decrease in account liquidity, according to TransUnion’s latest Debt Collection Industry Report. If the goals are implementing strategic operational efficiencies and improving the consumer experience to facilitate debt repayment, the means to the ends include investing in technologies like artificial intelligence, solving for scalability, and optimizing communication channels and consumer self-service engagement. For lenders and collectors, here are some recommendations for your debt collection strategy in 2025:

Scalability, Go Big or Go Home. Higher account volume calls for operations that can scale cost-effectively while offering the right consumer experience. Embracing smart technology is your best bet to keep up, and figuring out when to buy tech-enabled products and services versus when to invest in building it yourself will be key to making it work.

Reduce Friction for Consumers. Self-service portals in collections reduce friction and foster a sense of autonomy for consumers to manage their debt without the pressure or inconvenience of interacting with a call center agent. Besides creating a more streamlined experience for the consumer, organizations will also benefit from associated cost-savings, compliance controls and scalability.

Compliance Changes, Adapt or Perish. The debt collection industry experienced notable legal and compliance changes in 2024, including important litigation outcomes and updates to digital communications regulations, and keeping up with more changes to come will be critical to your business. Join our Legal and Compliance Roundup webinar on Jan. 29 to learn about the latest developments and how they will shape strategies and industry practices in 2025. Register here: https://bit.ly/4h4tacd

SOURCES:

Q3 Industry Insights: Inflation and Interest Rates Drop, Christmas Comes Early

By Mark Ravanesi on October 22nd, 2024 in Industry Insights, Compliance, Customer Experience

The big inflation situation plaguing the U.S. for the past three years seems to be coming to an end, and it could be that American consumers are partially to thank. Tired of paying higher prices, consumers increasingly turned to cheaper alternatives, bargain hunted or simply avoided items they found too expensive, pressuring retailers to accommodate them or lose their business. That’s not to say Americans have stopped spending altogether—the economy continues to expand and people continue to struggle against inflated prices for necessities across the board, often still turning to credit cards to make ends meet.

With consumers setting the demand amidst elevated prices and inflation declining slowly, retailers have gotten an even earlier jump on holiday promotions this year in the hopes of boosting sales in a price-wary environment. Spreading holiday expenses out over a longer period of time may ease the financial burden slightly, but the cumulative dollars spent will still weigh heavily on consumer finances for Q4 and rolling into 2025. The National Retail Federation is forecasting that winter holiday spending is expected to grow between 2.5% and 3.5% over last year, with a total reaching between $979.5 billion and $989 billion.

We are starting to feel an economic shift, but what does this all mean and what’s the outlook for the end of the year? Read on for our take on what’s impacting consumer finances, how consumers are reacting and what else you should be considering as it relates to debt collection today.

What’s Impacting Consumers?

While not the straight line decline economists would like to see, the September results show that inflation is slowly and steadily easing back to the Federal Reserve’s 2% target. After several months of decreasing inflation and amid slowing job gains, the Fed in September announced the first in a series of interest rate cuts, slashing the federal funds rate by 1/2 percentage point to 4.75-5%. Federal Reserve Chair Jerome Powell indicated that more interest rate cuts are in the plans but they would come at a slower pace, likely in quarter-point increments, intended to support a still-healthy economy and a soft landing.

The rate cut plans have been made possible by consistently declining inflation. The Consumer Price Index rose just 2.4% in September from last year, down from 2.5% in August, showing the smallest annual rise since February 2021. Core prices, which exclude the more volatile food and energy costs, remained elevated in September, due in part to rising costs for medical care, clothing, auto insurance and airline fares. But apartment rental prices grew more slowly last month, a sign that housing inflation is finally cooling and foreshadowing a long-awaited development that would provide relief to many consumers.

The September jobs report supported the economic optimism by adding a whopping 254,000 jobs, far exceeding economists’ expectations of 140,000. The unemployment rate lowered to 4.1%, below projections of remaining steady at 4.2%. The government has also reported that the economy expanded at a solid 3% annual rate Q2, with growth expected to continue at a similar pace in Q3. This combination of downward trending interest rates and unemployment plus an expanding economy is great news for consumers and businesses alike, and can’t come soon enough for many financially strained Americans.

Coming out of Q2, total household debt rose by $109 billion to reach $17.80 trillion, according to the latest Quarterly Report on Household Debt and Credit. This increase showed up across debt types: mortgage balances were up $77 billion to reach $12.52 trillion, auto loans increased by $10 billion to reach $1.63 trillion and credit card balances increased by $27 billion to reach $1.14 trillion.

Unsurprisingly, delinquency and charge-off rates ticked up as consumers struggled against still relatively high prices and interest rates. In mid-September, shares of consumer-lending companies slid after executives raised warnings about lower-income borrowers who are struggling to make payments. Delinquency transition rates for credit cards, auto loans and mortgages all increased slightly, with a steeper increase in flow to serious delinquency for credit cards, up more than 2% over last year from 5.08% to 7.18%. This kind of delinquency can be especially difficult for consumers to recover from given the record-high credit card rates many are stuck with.

While still low by historical standards, the mortgage delinquency rate was up 3 basis points in Q2 from the first quarter of 2024 and up 60 basis points from one year ago. The delinquency rate for mortgage loans increased to a seasonally adjusted rate of 3.97% at the end of Q2, according to the Mortgage Bankers Association’s (MBA) National Delinquency Survey, an increase that corresponded with a rise in unemployment and showed up across all product types.

For those with student loans, September marked the end of the ‘on-ramp’ to resuming payments, which was the set period of time that allowed financially vulnerable borrowers who missed payments during the first 12 months not to be considered delinquent, reported to credit bureaus, placed in default, or referred to debt collection agencies. However, the grace period is over and anyone who doesn’t resume making student loan payments in October risks a hit to their credit score—we will see these delinquencies reported in Q4.

Financial Protection for Consumers Across the Board

The Consumer Financial Protection Bureau (CFPB) continued with a high level of activity through the summer. Along with taking action against more than a handful of financial services companies in the name of consumer protection, the agency made headway on myriad other issues.

To kick off Q3, the CFPB published Supervisory Highlights sharing key findings from recent examinations of auto and student loan servicing companies, debt collectors and other financial services providers that found loan servicing failures, illegal debt collection practices and issues with medical payment products. The report also highlighted consumer complaints about medical payment products and identified concerns with providers preventing access to deposit and prepaid account funds.

Then, the CFPB and five other agencies issued a final rule on automated valuation models. The agencies, including the OCC, FRB, FDIC, NCUA, and FHA designed the rule to help ensure credibility and integrity of models used in valuations for certain housing mortgages. The rule requires adoption of compliance management systems to ensure a high level of confidence in estimates, protect against data manipulation, avoid conflicts of interest, randomly test and review the processes and comply with nondiscrimination laws.

Next, the CFPB joined several other federal financial regulatory agencies to propose a rule to establish data standards to promote “interoperability” of financial regulatory data across the agencies. The proposal would establish data standards for identifiers of legal entities and other common identifiers.

Also in August, the CFPB responded to the U.S. Treasury’s request for information on the use of artificial intelligence in the financial services sector. The CFPB emphasized that regulators have a legal mandate to ensure that existing rules are enforced for all technologies, including new technologies like artificial intelligence (AI) and its subtypes. It’s clear that the CFPB has an interest in how those technologies are used and what the consumer impact may be.

In September, the bureau issued its annual report on debt collection, which highlighted aggressive and illegal practices in the collection of medical debt and rental debt. The report focused on improperly inflated rental debt amounts and on debt collectors’ attempts to collect medical bills already satisfied by financial assistance programs, also noting that many medical bills from low-income consumers do not get addressed by financial assistance in the first place.

Finally, the CFPB published guidance to help federal and state consumer protection enforcers stop banks from charging overdraft fees without having proof they obtained customers’ consent. Under the Electronic Fund Transfer Act, banks cannot charge overdraft fees on ATM and one-time debit card transactions unless consumers have affirmatively opted in.

Disjointed Consumer Sentiment Weighs Heavy

A September Consumer Survey of Expectations found that Americans anticipated higher inflation over the longer run as their expectations of credit turbulence rose to the highest level since April 2020, according to the Federal Reserve Bank of New York. While perceptions and expectations for credit access improved, the expected credit delinquency rates rose again and hit the highest level in more than four years. According to the survey, the average expected probability of missing a debt payment over the next three months rose for a fourth straight month to 14.2%, up from 13.6% in August, suggesting some Americans are concerned with their ability to manage their borrowing.

Despite inflation easing, consumers perceive that the costs of everyday items are on the rise. According to the latest report from PYMNTS Intelligence, which tracks the percent of consumers living paycheck-to-paycheck, 70% of all consumers surveyed said their income has not kept up with inflation. This feeling is stronger for paycheck-to-paycheck consumers, with 77% of those struggling to pay bills on time reporting that their income hasn’t kept up with rising costs. Even for those not living paycheck to paycheck, 61% shared this concerning sentiment. As a result, consumers are buying cheaper or lesser quality alternatives, if they’re buying at all.

Prior to the September interest rate cuts, the Conference Board’s Consumer Confidence Index showed consumer confidence plunging to the most pessimistic economic outlook since 2021, based on a weaker job market and a high cost of living. Americans reported being anxious ahead of the upcoming election and assessments of current and future business conditions and labor market conditions turned negative.

However, following the Fed’s rate cut announcement, another report from the University of Michigan’s sentiment index showed a rise in late September, reaching a five-month high on more optimism about the economy. Consumer expectations for price increases dropped simultaneously with more expectations for declining borrowing costs in the coming year. Consumer sentiments on their finances directly impact their spending and payment behaviors, so understanding where they stand can inform a better debt collection approach.

What Does This Mean for Debt Collection?

You’ve heard of Christmas in July, but Christmas in September? With the holiday shopping season starting earlier and in the midst of a high-stakes election, consumers will continue to prioritize expenses and spending based on their current financial outlook, which hasn’t yet caught up with the optimism showing up in the overall economy. The unknowns of what happens post-election along with the delayed impact of lower interest rates and inflation on spending leave the outcome for consumer finances uncertain. Delinquencies continue to persist and it may be some time before the benefits of a friendlier economy show up in consumers’ bank accounts. For companies looking to recover delinquent funds now, understanding how, when and in what way to engage consumers can increase recovery success. For lenders and collectors, here are some things to consider for 2025 planning:

• Self-serve = more repayment. For both businesses and consumers, reducing the need to engage directly with human agents to make payments or access account information saves time and resources. Solutions like self-serve portals represent a shift towards greater consumer control over their financial health, providing an efficient way for individuals to address and manage their finances—and debts specifically—on their own terms.

• Omnichannel or bust. If your business relies solely on one channel for customer communications, it’s time to evolve. Utilizing a combination of calling, emailing, text messaging and even self-serve online portals is the preferred experience for 9 out of 10 customers. And it’s not just beneficial for consumers–the omnichannel approach has been shown to increase payment arrangements by as much as 40%!

• Keep an eye on compliance (or make sure your debt collector does). The regulatory landscape will continue to change, especially post-election. Your risk and success hinges on how well you can keep up with the changes, so having someone responsible for monitoring and tweaking your strategy is critical.

SOURCES:

Q2 Industry Insights: Beating the Economic Heat and Keeping Up with Compliance

By Mark Ravanesi on July 9th, 2024 in Industry Insights

The dog days of summer are ahead, and with inflation and high interest rates still sticking around, consumers in the U.S. will be feeling the heat financially. Consumer sentiment and data-based indicators tell some of the story, but what better way to gauge the consumer financial landscape than by looking at how people spend their free time and money?

While consumers embraced the ‘YOLO economy’ coming out of pandemic times – spending wildly on products and experiences – today’s high inflation, low savings and a cooling job market have shifted priorities for many, leading to weakened consumer spending. And businesses are responding accordingly to the lower demand – several top musical acts from Jennifer Lopez to the Black Keys have canceled summer tours due to low ticket sales while retailers like Walmart and Target are lowering prices on certain goods to appeal to budget-strained shoppers.

Despite families looking for ways to save this summer, their vacation plans must go on. The Transportation Security Authority has been anticipating and reporting record air travel numbers while a recent LendingTree survey found that 45% of parents go into debt to pay for a Disney vacation and few have regrets about it, indicating people will still prioritize spending for some experiences.

Meanwhile, the Consumer Financial Protection Bureau (CFPB) has been busy, with new rules impacting lenders and collectors across the spectrum. What does this all mean and what’s the outlook for the second half of the year? Read on for our take on what’s impacting consumer finances, how consumers are reacting and what else you should be considering as it relates to debt collection in 2024.

What’s Impacting Consumers?

Inflation finally started slowing in May and then showed a decline in June, landing at 3% from a year ago and the lowest level in more than three years. Both headline and core inflation beat forecasts but housing costs continued to rise and remain a key contributor to inflation. Being heavily weighted in the Consumer Price Index (CPI) formula, it’s unlikely to see big drops in CPI until these costs start to fall. In June, Federal Reserve officials held the key rate steady and penciled in a single rate cut this year while forecasting four in 2025, reinforcing calls to keep borrowing costs higher for longer. Meanwhile, the labor market has moved close to its pre-pandemic state and the overall economy continues to grow at a solid pace.

But even the 2% drop in the energy index won’t be enough to combat the inflated cost of keeping cool this summer, with predicted extreme heat set to drive home cooling costs up to a 10-year high. The average cost of keeping a home cool from June through September is set to reach $719, nearly 8% higher than last year and a big jump from the 2021 average of $573. Concerningly for lower-income households, organizations distributing federal financial support expect they’ll be able to help roughly one million fewer families pay their energy bills this year, in part due to government funding for the Low Income Home Energy Assistance Program (LIHEAP) falling by $2 billion from last fiscal year.

Coming out of Q1, total household debt rose by $184 billion to reach $17.69 trillion, according to the Federal Reserve Bank of New York’s latest Quarterly Report on Household Debt and Credit. Mortgage and auto loan balances continued climbing, increasing to $12.44 trillion and $1.62 trillion respectively. Overall, delinquency indicators decreased positively as we moved through Q2 as seasonally expected, partly due to tax season. In May, overall delinquent balances (30+ DPD) increased by 3.46%, driven by a 6.06% increase in delinquent mortgage balances. But mortgage was an exception, not the norm: there was a 0.55% decrease MoM in 30+ DPD delinquent accounts overall.

Credit card balances also declined seasonally as expected in Q1 to $1.12 trillion, but new delinquencies rose with nearly 9% of credit card balances and 8% of auto loans transitioning into delinquency. Despite this latest decrease, credit card balances are still up $259 billion since the fourth quarter of 2021. Thanks to record interest rates, stubborn inflation and other economic factors, credit card balances are likely only going to climb, despite what we saw in the first half of the year.

The verdict is still out on how those with student loans are faring with resumed payments. Missed federal student loan payments will not be reported to credit bureaus until the fourth quarter of 2024. Because of these policies, less than 1% of aggregate student debt was reported 90+ days delinquent or in default in the first half of the year and will remain low through the end of the year.

Busy Season at the CFPB

With a flurry of announcements in the past few months, the CFPB has been busy. The biggest win: a long-awaited United States Supreme Court decision came out in May ruling that the CFPB’s funding is constitutional, leaving the Bureau free to uphold its mission of protecting consumers and ensuring that all Americans are treated fairly by banks, lenders and other financial institutions.

On the consumer fairness front, and after releasing research showing that 15 million Americans still have medical bills on their credit reports despite changes by Equifax, Experian and TransUnion, the CFPB proposed a rule to ban medical bills from credit reports, a move that would remove as much as $49 billion of medical debts that unjustly lower consumer credit scores. In another attempt to help consumers by bringing homeownership back into reach amidst high interest rates and home prices, the CFPB also started an inquiry into mortgage junk fees and excessive closing costs that can drain down payments and push up monthly mortgage costs.

As related to business operations oversight, in June the CFPB issued a new circular on “unlawful and unenforceable contract terms and conditions in contracts for consumer financial products or services.” This warning makes it clear that it is a UDAAP (Unfair, Deceptive, or Abusive Acts or Practice) to have an unlawful, unenforceable term in contracts with consumers.

Later in June, the CFPB also finalized a new rule to establish a registry to detect and deter corporate offenders that have broken consumer laws and are subject to federal, state or local government or court orders. This registry will help the CFPB to identify repeat offenders and recidivism trends to hold businesses accountable as historically, nonbank entities faced inconsistent oversight, making it challenging for regulators to identify and address potential risks to consumers.

As the CFPB works to accelerate the shift to open banking in the United States, it also announced a new rule establishing a process for recognizing data sharing standards and preventing dominant incumbents from inhibiting startups.

At the end of June, the Supreme Court overturned the Chevron doctrine, a precedent that has allowed federal agencies like the CFPB significant authority to interpret ambiguous laws. This means that judges will use their own judgment to interpret laws rather than deferring to agency interpretations, making it easier to challenge and overturn agency regulations. As a result, the industry’s regulatory framework will become more unpredictable as courts take a larger role in interpreting laws and will require businesses to monitor and adapt their compliance and legal strategies.

A Roller Coaster of Consumer Sentiment

The first half of 2024 has been an economic roller coaster for consumer spending, resulting in whiplash for consumer sentiment. While the soft landing may still be on track, that track doesn’t appear to be as straightforward as hoped. There is an onslaught of mixed messages from, “consumers are proving to be more resilient than expected as they continue to spend, staving off what had been predicted to be an inevitable recession” to “consumers are actually financially stretched from depleting their pandemic-era savings and battling ongoing inflation and higher interest rates”.

The latest Paycheck-to-Paycheck report from PYMNTS Intelligence found that as of March, 58% of all U.S. consumers live paycheck to paycheck, regardless of their income levels. Causes for this financial situation vary and range from insufficient income and family dependents to large debt balances and splurging unnecessarily. While financial goals also vary across consumer segments, paying down debt is one common goal across all generations: 15% of Gen Z, 20% of millennials, 23% of Gen X and 22% of baby boomers and seniors said repaying debt is a priority.

Recent consumer surveys have found that 22% of respondents expressed feeling less discomfort about spending a lot of money when using a credit card, and more than half reported they are more likely to make impulse purchases when using cards. Whatever the sentiment, people are feeling some confidence to continue to spend and continue to carry a debt balance, with 41% of consumers reporting a revolving month-to-month balance on their credit cards.

What Does This Mean for Debt Collection?

Between these highs and lows of economic indicators and consumer sentiment, a serious fact remains for businesses: delinquency will continue to be an issue through 2024. For companies looking to recover those delinquent funds, understanding how to communicate with consumers where they are in this roller coaster can mean the difference between repayment and write-off. For lenders and collectors, here are some things to consider:

Shift the collection mindset. Pivoting debt resolution operations from only being focused on roll rates and placements to a more consumer-centric engagement strategy is the first critical step to productively engaging consumers.

Customization is key. Effective debt recovery communications will resonate with consumers and match where individuals are with the right message to engage with empathy and options for repayment; the right channel to engage through their preferred method of communication; and the right time to engage on their own terms when they are ready.

Don’t skimp on compliance. Not only does following the rules of debt collection keep you out of hot water, adhering to the consumer-friendly rules will set up the best possible experience for consumers, leading to better engagement and repayment rates. Here’s a comprehensive look at what you need to know about collections compliance to get started.

SOURCES:

New York Times
ABC News
CNBC
USA Today
NBC News
Federal Reserve Bank of New York
Experian Ascend Market Insights Dashboard, Release 97
United States Supreme Court
CFPB – Medical Bills
CFPB – Unlawful Contract Terms
CFPB – Open Banking Standards
AccountsRecovery.net
PYMNTS.com
Payments Journal
USA Today / LendingTree

Q1 Industry Insights: Persistent Inflation is Bananas and a Tale of Two Consumers

By Mark Ravanesi on April 15th, 2024 in Industry Insights

Way back in January, 2024 was looking strong with decreasing inflation holding the promise of interest rate cuts that would ease the strain on consumer finances and reopen a tight market. Three months into the year, the outlook isn’t looking quite as rosy, but optimism for change persists. While the looming threat of a recession has passed, the outlook seems to point to inflation sticking around and consumer sentiment on the financial outlook this year is mixed. Case in point – even Trader Joe’s gave in and raised the price of bananas, from 19 to 23 cents, for the first time in 20 years, with loyal shoppers calling the move “the end of an era”. The Federal Reserve is still poised for a couple of rate drops this year, though the timing and impact of those are more in question, especially with the resilient labor market that could push interest rate cuts to later in the year to ensure inflation is truly tamed before acting and the global conflicts that are impacting Wall Street and interest rates.

The first quarter of the year coincides with tax season, when many consumers realize a tax refund that helps the strain on finances, which in turn produces an uptick in debt repayment. Strong liquidation rates this quarter don’t necessarily signal how the following months will perform. How has the economy impacted consumers this quarter and what’s in store for the rest of the year? Read on for our take on what’s impacting consumer finances, how consumers are reacting, and what else you should be considering as it relates to debt collection in 2024.

What’s Impacting Consumers?

Inflation persisted in Q1. The Labor Department’s Bureau of Labor Statistics reported that CPI rose 0.4% in March, bringing the 12-month inflation rate to 3.5%, or 0.3% higher than in February. This increase was driven by shelter and energy costs, with energy rising 1.1% after climbing 2.3% in February, while shelter costs increased by 0.4%, up 5.7% from a year ago. The Fed has been expecting shelter-related costs to decelerate through the year, which would allow for interest rate cuts, so this rising indicator is not favorable for consumer economic outlook.

Consumers kicked the year off with debt trending higher. According to the Federal Reserve Bank of New York’s latest Quarterly Report on Household Debt and Credit, total household debt rose by $212 billion to reach $17.5 trillion in Q4 of 2023 and credit card balances increased by $50 billion to a record $1.13 trillion. Mortgage and auto loan balances also rose, with the Bank saying the data indicates financial distress is on the rise, particularly among younger and lower-income Americans.

The emerging situation is what recent reports have dubbed “a tale of two consumers”. One consumer cohort is the roughly two-thirds of Americans who have done substantially well, own their homes and/or have invested in the stock market – this group had the savings cushion necessary to weather high inflation. The other cohort, made up of mostly middle- and lower-income renters who have not benefited from the wealth effect of higher housing and stock prices, has been hit harder by inflation and is feeling more financial stress.

Experts worry that members of this second cohort are falling behind on their debts and could face further deterioration of their financial health in the year ahead, particularly those who have recently resumed paying off student loans. While approximately 4 million relieved Americans have benefitted from $146 billion in student debt relief as a result of the Biden-Harris Administrations myriad executive actions, millions more are still left trying to add resumed payments back into their budgets amidst a stubbornly high cost of living.

To cover this additional monthly debt, 33% of surveyed consumers with student loans planned to reduce discretionary spending or use their savings; 28% said they would get a second job or do part-time or temporary work; 25% will use money from retirement savings; 21% will use credit card available limits; and 19% will borrow from family or friends, or delay a key milestone like marriage or home purchase. For those who expect student loan forgiveness, 57% surveyed say they would use savings from forgiveness to pay off debt, 10% would put the savings toward a home purchase, 26% say they would put savings toward other savings and 7% say they would spend their savings on other things, according to the Federal Reserve’s latest Survey of Household Economics and Decisionmaking.

A Growing Mountain of Credit Card Debt and Other Indicators

For consumers who turn to credit cards to make ends meet, higher interest rates are making it more costly to carry a balance on a credit card, with the average credit card APR at a record 24.66%. Debt holders are also carrying their debt for longer periods of time, and struggle to pay it off as it compounds. According to a LendingTree analysis of more than 350,000 credit reports, the average unpaid credit card balance was $6,864 in Q4 2023.

This starts showing up in increased credit card delinquencies, which soared more than 50% by the end of 2023, with about 6.4% of all accounts 90 days past due, up from 4% at the end of 2022. Delinquency transition rates also increased for almost all other debt types, with the exception of student loans. According to Experian’s Ascend Market Insights, overall 30+ days past due delinquency grew, starting the year with a 2.31% increase in delinquent accounts and 10.49% increase in delinquent balances month over month. Q1 of 2024 is also showing a rise in early-stage delinquencies, ticking up from 0.98% in January to 1.04% in February.

Missing payments correlate to another indicator of consumer financial health – the U.S. personal saving rate dipped down to 3.6% in February, compared to 4.1% in January and 4.7% in 2023. The situation remains that a majority of U.S. consumers (59%) live paycheck to paycheck as of February 2024, including 42% of those earning more than $100,000 per year. As an alternative to taking on debt, many Americans are taking on side jobs to increase income instead – as of February 2024, 22% of workers had a side job. The data also shows that 30% of employed consumers earning supplemental income depend on this money to make ends meet, up from 25% last year.

Consumers Worried About Inflation and Debt Accumulation

Unsurprisingly, 82% of consumers surveyed say concerns about inflation top their lists of economic woes, with only 17% holding out any hope that inflation will subside anytime soon. One of the few solutions available to consumers hoping to fight back against inflation is an increase in their paycheck, but the report found that fewer than 4 in 10 consumers anticipated a wage increase this year, down from 43% who expected a raise last year. According to the latest Compensation Best Practices Report, 79% of organizations are planning to give pay increases in 2024—the lowest number in years—in light of a strong labor market and cooling inflation, down from 86% in 2023. And the amount of raises planned for this year are generally smaller, with organizations predicting an average base pay increase of 4.5%, compared to the average of 4.8% given in 2023.

A slim majority of Americans (56%) reported optimism about their household finances in the next 12 months, according to TransUnion’s Consumer Pulse Survey from Q4 2023. Millennials had the highest optimism among generations (71%) while Baby Boomers had the lowest (44%). Millennial optimism likely spurred from reported income increases and expected higher income growth in the next 12 months.

The Conference Board reported a mixed bag of consumer sentiment, with assessments of the present situation improving in March, primarily driven by more positive views of the current employment situation, while expectations for the next six months deteriorated. PYMNTS Intelligence data found that 15% of consumers say debt accumulation was a main pressure point on their savings, having dipped into those accounts to ease their debt burdens.

What Does This Mean for Debt Collection?

With a mixed and uncertain economic outlook, consumers will be watching their finances closely. While some populations may reap wealth effect benefits and fare well financially, others will face headwinds with sticky high prices and student loan payments. For debt collectors, it will be critical to provide the right experience for each consumer and understand that everyone has a different financial situation with different considerations. While the first quarter may have brought increased liquidation due to cash influxes from tax season, the following months may bring challenges. We’ll soon find out, but as a lender or collector, here are some things to consider:

Personalize your messages. What works for one consumer won’t necessarily work for the next. Consider the customer journey and tailor messaging so it resonates with consumers at different points in the debt collection process. It’s not just what you say, but how and when you say it that will determine how consumers respond. Learn more about the stages of the debt resolution funnel.

Give options. For consumers balancing tight finances, paying a lump sum may not be possible. Payment plans facilitate smaller payments over time that consumers can work into their budgets. Other options like choosing what day to pay and the ability to reschedule a payment will also help consumers stay on track to repayment.

Make it easy. When paying back debt is as simple as click→review→pay online, consumers will be more likely to engage. Using digital channels and giving consumers the pertinent information upfront so they can engage when and how they prefer means cutting out the middleman and empowering consumers to self-serve. 96% of consumers working with TrueAccord resolve their accounts without speaking to a human and often at times outside of standard customer service hours.

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