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I recently spoke at two different conferences for credit unions. During both speeches, I asked the audiences (approximately 125 people at one and 105 at the other) if they were aware that the CFPB was considering rules to regulate first-party collections. I also asked if they were aware of the current proposed rules for both first-party and third-party collections, which include rules on debt substantiation and transfer of data. Only five to 10 people raised their hands at each session. 

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