Policy Shift Removes Interpretations on Medical, Time-Barred Debt and More

In spring 2025, the CFPB took the unusual step of withdrawing 67 guidance documents, part of a house-cleaning under its new leadership. Among the scrapped materials were several bulletins and advisory opinions that had clarified (or tightened) expectations on debt collection and credit reporting. Notably, the Bureau rescinded guidance on “deceptive and unfair collection of medical debt” (issued Oct 2024) and on collection of time-barred debt (from 2023).

Also gone was an interpretation around “pay-to-pay” fees (convenience fees for making payments) which the CFPB had previously eyed as potentially unfair. By stripping these from the books, the CFPB signaled a return to a more literal enforcement of the written law (FDCPA and Reg F) without extra commentary.

For credit union collections shops, this pullback could simplify compliance in some areas. For instance, under prior guidance, attempting to collect on an ancient, statute-barred debt – even without suing – was risky, but the removal of that guidance adds some gray area (though collectors still must avoid deception about whether a debt is enforceable).

Similarly, while the CFPB had been leaning on medical debt collectors to curb aggressive credit reporting, the formal removal of that stance might reduce pressure in the short term. However, experts caution that “no guidance” doesn’t equal “no rule” – the underlying laws still apply, and UDAAP (unfair, deceptive, or abusive acts or practices) standards remain in place even if spelled out less. Many credit unions are continuing to follow the best practices outlined previously (like transparency about time-barred debt) as a prudent measure.

Takeaway: The CFPB’s mass withdrawal of guidances in 2025 provides regulatory relief and flexibility, but it’s not a green light to return to bad habits. Collections managers should stay on the ethical course – the lack of specific guidance means relying on general principles and ensuring member treatment stays fair and respectful, as examiners can still act if they find egregious practices.