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1.3.3 Original Creditors

Original creditors are entities that provide extensions of credit such as banks, credit unions, student loan lenders, auto lenders, and payday lenders. Additionally, some original creditors provide goods or services on credit, such as utility companies, medical providers, and cell phone companies.

Original creditors frequently employ people in-house to collect on their delinquent accounts. In a survey of credit card issuers conducted by the CFPB, all respondents conducted at least some collection activity in-house.141 Nationally, the Bureau of Labor Statistics estimates that nearly 300,000 people are employed as “bill and account collectors.”142

While original creditors collecting their own debts are not typically covered under the Fair Debt Collection Practices Act,143 the CFPB has made clear that its authority to prohibit unfair, deceptive, or abusive acts or practices (UDAAPs) under the Dodd Frank Act extends to original creditors.144 Moreover, original creditors collecting their own debts may be covered under state laws.145


  • 141 Consumer Fin. Protection Bur., The Consumer Credit Card Market 248 (Dec. 2015).

  • 142 Bur. of Labor Statistics, 43-3011 Bill and Account Collectors (May 2016), available at See also Consumer Fin. Protection Bur., The Consumer Credit Card Market, 239 (Dec. 2015) (citing older data from the Bureau of Labor Statistics).

  • 143 But see § 4.2.5, infra (discussing coverage for creditors using false names).

  • 144 Consumer Fin. Protection Bur., Bulletin 2013-7: Prohibition of Unfair, Deceptive, or Abusive Acts or Practices in the Collection of Consumer Debts (July 10, 2013). See also Appx. B.3.2, infra.

  • 145 See § (coverage under state debt collection laws), § (coverage under state UDAP laws).