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OPENING PARAGRAPH: Re: Comment from Texas Appleseed regarding notice of proposed rulemaking for debt collection, Docket No. CFPB-2019-0022 or RIN 3170-AA41. Dear Director Kraninger, Texas Appleseed is a public interest justice center working to change unjust laws and policies that prevent Texans from realizing their full potential. Working with pro bono partners and collaborators, Texas Appleseed develops and advocates for innovative and practical solutions to complex issues. As part of its work, Texas Appleseed also conducts data-driven research to better understand inequities and identify solutions for concrete, lasting change. Texas Appleseed is part of a non-profit network of 17 justice centers in the United States and Mexico. Through its Fair Financial Services Project, Texas Appleseed is a state leader in advocating for fair market practices across many financial services areas, including payday and auto title lending, protections for victims of financial abuse, and in support of fair debt collection practices. We appreciate the effort put in by the CFPB in drafting an expansive proposed debt collection rule, but have deep concerns that certain provisions will lead to market outcomes that go counter to the consumer protection mission of the CFPB and to the letter and intent of the Fair Debt Collections Practices Act. We are particularly concerned about four provisions in the proposed rule. We are concerned about provisions in the proposed rule that:

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