Regulated entities should be prepared to defend their policies and practices surrounding fee-based pay-by-phone options in light of new guidance issued by the Consumer Financial Protection Bureau.
The CFPB released a compliance bulletin on July 31 to provide guidance on charging pay-by-phone fees. In a press release, the CFPB touts the bulletin as a warning against “tricking consumers into expensive pay-by-phone fees,” which is also a succinct way to describe the CFPB’s take on the conduct it identifies in the bulletin. The bulletin highlights the risks of potential violations of Dodd-Frank’s UDAAP prohibition or the FDCPA posed by charging pay-by-phone fees.
