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1 Prosperity Now is a national nonprofit organization based in Washington, DC that works to expand economic opportunity for millions of people, especially people of color and those of limited incomes, to achieve financial security, stability and, ultimately, prosperity. We offer a unique combination of scalable practical solutions, in-depth research and proven policy solutions, all aimed at building wealth for those who need it most. In addition, Prosperity Now is committed to partnerships with our movement of committed advocates and practitioners seeking to create a clear path to financial stability, wealth and prosperity. Today, the Prosperity Now Community brings together more than 24,000 practitioners, advocates and researchers across all 50 states and DC to forge strong connections between those in our Community and mobilize action to create lasting social change. The Community includes Networks that bring together peers and other experts to share information, alerts and promising practices around financial coaching, adult matched savings, community tax preparation, racial wealth equity, affordable homeownership and more. 2 The proposed rulemaking concerns third party debt collectors, not the creditor that originated the debt. 3 “Consumers with Collections,” Prosperity Now Scorecard, accessed August 27, 2019, https://scorecard.prosperitynow.org/data-by-issue#finance/outcome/consumers-with-collections 4 “Severely Delinquent Borrowers,” Prosperity Now Scorecard, accessed August 27, 2019, https://scorecard.prosperitynow.org/data-by-issue#finance/outcome/severely-delinquent-borrowers 5 “Severely Delinquent Student Loan Debt,” Prosperity Now Scorecard, accessed August 27, 2019, https://scorecard.prosperitynow.org/data-by-issue#education/outcome/severely-delinquent-student-loan-debt 6 Hannah Hassani and Signe-Mary McKernan, “71 million US adults have debt in collections,” Urban Institute, July 2018, https://www.urban.org/urban-wire/71-million-us-adults-have-debt-collections 7 https://scorecard.prosperitynow.org/data-by-issue#finance/outcome/severely-delinquent-borrowers 8 https://scorecard.prosperitynow.org/data-by-issue#education/outcome/severely-delinquent-student-loan-debt 9 Market Snapshot: Third-Party Debt Collections Tradeline Reporting (Washington, DC: CFPB, July 2019), https://files.consumerfinance.gov/f/documents/201907_cfpb_third-party-debt-collections_report.pdf 10 https://files.consumerfinance.gov/f/documents/201701_cfpb_Debt-Collection-Survey-Report.pdf 11 Consumer Experiences with Debt Collection: Findings from the CFPB’s Survey of Consumer Views on Debt (Washington, DC: CFPB, January 2017), https://files.consumerfinance.gov/f/documents/201701_cfpb_Debt-Collection-Survey-Report.pdf

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12 Debt in America: An Interactive Map (Washington, DC: Urban Institute, December 2018), https://apps.urban.org/features/debt-interactive-map/ 13 “Auto Loan Debt,” Debt in America: An Interactive Map, https://apps.urban.org/features/debt-interactive-map/?type=auto&variable=autoopen_pct 14 “Medical Debt,” Debt in America: An Interactive Map, https://apps.urban.org/features/debt-interactive-map/?type=medical&variable=perc_debt_collect 15 “Student Loan Debt,” Debt in America: An Interactive Map, https://apps.urban.org/features/debt-interactive-map/?type=student&variable=perc_stud_debt 16 “Liquid Asset Poverty Rate,” Debt in America: An Interactive Map, https://scorecard.prosperitynow.org/data-by-issue#finance/outcome/liquid-asset-poverty-rate 17 Emanuel Nieves and Dedrick Asante-Muhammad, “Running in Place: Why the Racial Wealth Divide Keeps Black and Latino Families From Achieving Economic Security” (Washington, DC: Prosperity Now, 2018), https://prosperitynow.org/sites/default/files/resources/Running_in_Place_FINAL_3.2018.pdf. 18 CFPB Survey on Consumer Experiences with Debt 19 Paul Kiel and Annie Waldman, “The Color of Debt: How Collection Suits Squeeze Black Neighborhoods,” ProPublica, October 2015, https://www.propublica.org/article/debt-collection-lawsuits-squeeze-black-neighborhoods 20 Spectra Myers and Pamela Chan, “Overdue: Addressing Debt in Black Communities” (Washington, DC: Prosperity Now, August, 2018), https://prosperitynow.org/sites/default/files/resources/Addressing_Debt_in_Black_Communities_1.pdf 21 Debt Collection Agencies Industry in the US – Market Research Report (New York, NY: IBISWorld, June 2019), https://www.ibisworld.com/industry-trends/market-research-reports/administration-business-support-waste-management-services/administrative/debt-collection-agencies.html 22 Fair Debt Collection Practices Act: BCFP Annual Report 2019 (Washington, DC: CFPB, March 2019), (https://files.consumerfinance.gov/f/documents/cfpb_fdcpa_annual-report-congress_03-2019.pdf 23 https://www.ftc.gov/system/files/documents/reports/consumer-sentinel-network-data-book-2018/consumer_sentinel_network_data_book_2018_0.pdf 24 CFPB Survey on Consumer Experiences with Debt 25 Key Dimensions and Processes in the U.S. Credit Reporting System: A review of how the nation’s largest credit bureaus manage consumer data (Washington, DC: CFPB, December 2012), https://files.consumerfinance.gov/f/201212_cfpb_credit-reporting-white-paper.pdf 26 Report to Congress Under Section 319 of the Fair and Accurate Credit Transactions Act of 2003 (Washington, DC: Federal Trade Commission (FTC), December 2012), https://www.ftc.gov/sites/default/files/documents/reports/section-319-fair-and-accurate-credit-transactions-act-2003-fifth-interim-federal-trade-commission/130211factareport.pdf 27 BCFP Annual Report 2019 28 Jake Halpern, “Paper Boys: Inside the Dark, Labyrinthine, and Extremely Lucrative World of Consumer Debt Collection,” New York Times, August 2014, https://www.nytimes.com/interactive/2014/08/15/magazine/bad-paper-debt-collector.html 29 CFPB and the New York Attorney General Settle with Debt Collection Group, CFPB Newsroom, July 2019, https://www.consumerfinance.gov/about-us/newsroom/cfpb-and-new-york-attorney-general-settle-debt-collection-group/ 30 Market Snapshot: Online Debt Sales (Washington, DC: CFPB, January 2017), https://files.consumerfinance.gov/f/documents/201701_cfpb_Online-Debt-Sales-Report.pdf 31 David Newville and Anju Chopra, “Abusive Debt Collection Practices Hurt Vulnerable Consumers” (Washington, DC: Prosperity Now, Updated December 2016), https://prosperitynow.org/sites/default/files/PDFs/policy-brief_abusive_debt_collection_practices.pdf 32 CFPB Survey on Consumer Experiences with Debt 33 Ibid 34 Brian Stauffer, “Rubber Stamp Justice: US Courts, Debt Buying Corporations, and the Poor,” Human Rights Watch, January 2016, https://www.hrw.org/report/2016/01/20/rubber-stamp-justice/us-courts-debt-buying-corporations-and-poor 35 Tom Feltner, Julia Barnard, and Lisa Stifler, Debt By Default: Debt Collection Practices in Washington 2012-2016 (Durham, NC: Center for Responsible Lending, March 2019), https://www.responsiblelending.org/sites/default/files/nodes/files/research-publication/crl-washington-debt-by-default-15mar2019.pdf 36 Stauffer, “Rubber Stamp Justice” 37 Peter A. Holland, “Junk Justice: A Statistical Analysis of 4,400 Lawsuits Filed by Debt Buyers,” Loyola Consumer Law Review, March 2014, https://core.ac.uk/download/pdf/56360427.pdf