Due to new sweeping regulations including Regulation F by the Consumer Financial Protections Bureau (CFPB) starting December 1st, Oxygen has started implementing these rules. The most critical rule that is relevant to our clients is the itemization date on all new consumer accounts being sent over to us. (This rule is not relevant to commercial collection accounts)
What is the itemization date?
The itemization date should be a date that the consumer in default – should recognize. The CFPB has defined the following itemization dates and requires creditors to use one of these below:
We are diligently working on updated placement forms to reflect the sweeping changes enacted and will share those with our clients shortly.
Itemization dates in more detail:
The following is an example of debt incurred via rental arrears, however the same rules apply to other debt types, for example – medical, gym or other consumer credit transactions.
When a tenant vacates the apartment, the Creditor is required to use one of the above dates to ascertain the itemization date. It could be the date when Creditor charges it off on their accounting system. Any further charges after the Charge off date, MUST be sent over itemized.
If the Creditor prefers using the ‘Last statement date’ that date must appear on the statement. Any subsequent charges must be itemized when sending it over to Oxygen XL.
If the Creditor is using the Last Charge Date, then any further charges after that date, must be itemized when sent over for collections.
If Creditor is unable to provide a clear itemization date as per the above or wishes to add additional charges after the charge off date, but is unable to provide it itemized, unfortunately per the new rules by the CFPB, Oxygen XL will be unable to accept the account for collections.
For further questions or concerns about the new rule, feel free to contact our Client Services Department on 845-579-2950 x 208 or email Clientservices@oxygenxl.com