When “Too Big to Fail” Makes Others “Too Small to Succeed”

Whether unintended or not, the CFPB’s Rules and Bulletins are driving small businesses from the debt collection industry. As we knew, the CFPB’s Larger Non-Bank Participant Rule would have a direct impact on small businesses and law firms. Whether your business or law firm is a large or small participant in the debt collection space, as a provider of any “material service” to a larger participant you are deemed a “service provider” and subject to examination and enforcement by the CFPB. <more>