This section of the FEDERAL REGISTER

contains regulatory documents having general

applicability and legal effect, most of which

are keyed to and codified in the Code of

Federal Regulations, which is published under

50 titles pursuant to 44 U.S.C. 1510.

The Code of Federal Regulations is sold by

the Superintendent of Documents.

Rules and Regulations Federal Register

39733 

Vol. 87, No. 127 

Tuesday, July 5, 2022 

1Public Law 95–109, sec. 802(e), 91 Stat. 874, 874 

(codified at 15 U.S.C. 1692(e)). 

2 15 U.S.C. 1692(a), (b). See also S. Rep. No. 95– 

382, at 2 (1977) (stating that ‘‘debt collection abuse 

by third party debt collectors [was] a widespread 

and serious national problem,’’ which Congress 

largely attributed to a ‘‘lack of meaningful 

legislation on the State level’’). 

3 15 U.S.C. 1692f. 

4 15 U.S.C. 1692f(1). 

5See 15 U.S.C. 1692l(a) (2010). 

6Public Law 111–203, sec. 1089, 124 Stat. 1376, 

2093 (codified at 15 U.S.C. 1692l(b)(6)). 

7 15 U.S.C. 1691l(d). 

8See Debt Collection Practices (Regulation F), 85 

FR 76734 (Nov. 30, 2020); Debt Collection Practices 

(Regulation F), 86 FR 5766 (Jan. 19, 2021). 

9 85 FR 76734, 76833. 

10 Id. at 76833, 76892. 

11CFPB Compliance Bulletin 2017–01, 82 FR 

35936, 35936 (Aug. 2, 2017). 

12 Id. at 35938. 

13 Id. (explaining that the CFPB examiners had 

instructed the company to collect pay-by-phone 

fees only ‘‘where expressly authorized by contract 

or state law’’); see also CFPB: Fall 2014 Supervisory 

Highlights, at 7, available at https://files.consumer

finance.gov/f/201410_cfpb_supervisory-highlights_

fall-2014.pdf (similar); CFPB: Fall 2015 Supervisory 

Highlights, at 20–21, available at https:// 

Continued 

BUREAU OF CONSUMER FINANCIAL 

PROTECTION 

12 CFR Part 1006 

Debt Collection Practices (Regulation 

F); Pay-to-Pay Fees 

AGENCY: Bureau of Consumer Financial 

Protection. 

ACTION: Advisory opinion. 

SUMMARY: Section 808(1) of the Fair 

Debt Collection Practices Act (FDCPA or 

Act) prohibits debt collectors from 

collecting any amount (including any 

interest, fee, charge, or expense 

incidental to the principal obligation) 

unless that amount is expressly 

authorized by the agreement creating 

the debt or permitted by law. The 

Consumer Financial Protection Bureau 

(CFPB) issues this advisory opinion to 

affirm that this provision prohibits debt 

collectors from collecting pay-to-pay or 

‘‘convenience’’ fees, such as fees 

imposed for making a payment online or 

by phone, when those fees are not 

expressly authorized by the agreement 

creating the debt or expressly 

authorized by law. This advisory 

opinion also clarifies that a debt 

collector may also violate section 808(1) 

when the debt collector collects pay-topay fees through a third-party payment 

processor. 

DATES: This advisory opinion is 

effective on July 5, 2022. 

FOR FURTHER INFORMATION CONTACT: 

Sonya Pass, Senior Legal Counsel and 

Chief of Staff, Legal Division, (202) 435– 

7700. If you require this document in an 

alternative electronic format, please 

contact CFPB_Accessibility@cfpb.gov. 

SUPPLEMENTARY INFORMATION: 

I. Advisory Opinion

A. Background

Congress enacted the FDCPA in 1977

to ‘‘eliminate abusive debt collection 

practices by debt collectors, to insure 

that those debt collectors who refrain 

from using abusive debt collection 

practices are not competitively 

disadvantaged, and to promote 

consistent State action to protect 

consumers against debt collection 

abuses.’’ 1 The statute was a response to 

‘‘abundant evidence of the use of 

abusive, deceptive, and unfair debt 

collection practices by many debt 

collectors,’’ which Congress attributed 

to the ‘‘inadequacy’’ of ‘‘existing laws 

and procedures,’’ including State laws.2

To remedy this, the FDCPA imposes 

various requirements and restrictions on 

debt collectors’ debt collection activity. 

Relevant here is section 808, which 

provides that a ‘‘debt collector may not 

use unfair or unconscionable means to 

collect or attempt to collect any debt.’’ 3

Section 808 then states that ‘‘[w]ithout 

limiting the general application of the 

foregoing, the following conduct is a 

violation of this section’’ and 

enumerates eight specifically prohibited 

practices, including the ‘‘collection of 

any amount (including any interest, fee, 

charge, or expense incidental to the 

principal obligation) unless such 

amount is expressly authorized by the 

agreement creating the debt or permitted 

by law.’’ 4

At the time of the FDCPA’s 

enactment, the Federal Trade 

Commission (FTC) was the agency that 

administered, and had primary 

responsibility for enforcing, the 

FDCPA.5 Then, in 2010, Congress 

passed the Dodd-Frank Wall Street 

Reform and Consumer Protection Act, 

which created the CFPB and granted it 

authority to administer, implement, and 

enforce the FDCPA.6 Congress also 

provided the CFPB authority to 

prescribe rules under the FDCPA.7

Pursuant to that authority, in 2020, the 

CFPB issued Regulation F, which 

implements the FDCPA, to prescribe 

rules governing the activities of debt 

collectors.8 The CFPB implemented 

FDCPA section 808(1) at 12 CFR 

1006.22(b) by ‘‘generally mirror[ing] the 

statute, with minor wording and 

organizational changes for clarity.’’ 9 In 

particular, the CFPB stated that the 

‘‘term ‘any amount’ includes any 

interest, fee, charge, or expense 

incidental to the principal 

obligation.’’ 10

In 2013, the CFPB launched its 

supervisory program over certain larger 

participants in the consumer debt 

collection market. Through these 

examinations, the CFPB ascertains 

compliance with the FDCPA, and now 

Regulation F, as well as other Federal 

consumer financial laws. The CFPB also 

periodically publishes Supervisory 

Highlights with anonymized findings 

and analysis from these supervisory 

examinations, as well as compliance 

bulletins to provide entities with 

guidance on complying with certain 

legal requirements. 

For example, in 2017, the CFPB 

issued a compliance bulletin (Bulletin) 

that ‘‘provides guidance to debt 

collectors about compliance with the 

[FDCPA] when assessing phone pay 

fees,’’ a type of pay-to-pay fee.11 The 

Bulletin summarizes CFPB staff’s 

conclusion that, under section 808(1), 

debt collectors may collect such pay-topay fees only if the underlying contract 

or state law expressly authorizes those 

fees.12 In particular, the Bulletin states 

that in at least one supervisory exam, 

CFPB examiners found that a debt 

collector ‘‘violated [section 808(1)] 

when they charged fees for taking 

mortgage payments over the phone’’ 

where the underlying contracts creating 

the debt did not expressly authorize 

collecting such fees and where the 

relevant State law did not ‘‘expressly 

permit collecting such fees.’’ 13


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39734 Federal Register / Vol. 87, No. 127 / Tuesday, July 5, 2022 / Rules and Regulations 

files.consumerfinance.gov/f/201510_cfpb_

supervisory-highlights.pdf (similar). 

14 15 U.S.C. 1692f(1) (emphasis added). See also 

12 CFR 1006.22(b). 

15Ali v. Fed. Bur. of Prisons, 552 U.S. 214, 219 

(2008) (quoting United States v. Gonzales, 520 U.S. 

1, 5 (1997), in turn quoting Webster’s Third New 

International Dictionary 97 (1976)). 

16 Include, Black’s Law Dictionary (11th ed. 

2019). Additionally, as the Supreme Court has 

stated, ‘‘including’’ is ‘‘not [a term] of all-embracing 

definition, but connotes simply an illustrative 

application of the general principle.’’ Fed. Land 

Bank of St. Paul v. Bismarck Lumber Co., 314 U.S. 

95, 100 (1941); see also Arizona State Bd. For 

Charter Schools v. Dep’t of Educ., 464 F.3d 1003, 

1007 (9th Cir. 2006) (‘‘[T]he word ‘including’ is 

ordinarily defined as a term of illustration, 

signifying that what follows is an example of the 

preceding principle.’’); United States v. Hawley, 919 

F.3d 252, 256 (4th Cir. 2019) (explaining that 

‘‘including’’ ‘‘is an introductory term for an 

incomplete list of examples’’). 

17The CFPB notes that, if a debt collector is 

engaged in a truly separate transaction and is not 

collecting or attempting to collect a debt covered by 

the FDCPA, section 808(1) does not apply. 

18See, e.g., Flores v. Collection Consultants of 

Cal., No. SA CV 14–0771–DOC, 2015 WL 4254032, 

at 10 (C.D. Cal. Mar. 20, 2015); Shula v. Lawent, 359 

F.3d 489, 492–93 (7th Cir. 2004). In Shula, it does 

not appear that that court was presented with the 

question whether ‘‘any amount’’ included more 

than ‘‘fees . . . incidental to the principal 

obligation’’; nor did that court analyze the issue. 

For the reasons stated above, the CFPB disagrees 

with that decision to the extent it suggested that 

section 808(1) applies only to amounts that are 

incidental to the principal obligation. 

19Section 808(1) of the FDCPA and Regulation F, 

12 CFR 1006.22(b), also covers pay-to-pay fees for 

the separate reason that such fees are ‘‘incidental 

to’’ the principal obligation. While the FDCPA does 

not define ‘‘incidental,’’ it is ordinarily understood 

as ‘‘related to,’’ see Collins English Dictionary (12th 

ed. 2014), or ‘‘[s]ubordinate to something of greater 

importance,’’ see Black’s Law Dictionary (11th ed. 

2019). Pay-to-pay fees meet these definitions: They 

are ‘‘related to’’ the principal obligation because 

they are fees charged for paying the principal 

obligation. Indeed, if the principal obligation did 

not exist, then neither would the pay-to-pay fee. 

These fees are also generally minor in comparison 

to the outstanding debt and are therefore 

‘‘subordinate to’’ the principal obligation. 

20 15 U.S.C. 1692f(1) (emphasis added). See also 

12 CFR 1006.22(b). 

21Permit, Webster’s Third New International 

Dictionary 1683 (1976); see also Permit, Black’s Law 

Dictionary (5th ed. 1979) (defining ‘‘permit’’ as ‘‘[t]o 

suffer, allow, consent, let; to give leave or license; 

to acquiesce, by failure to prevent, or to expressly 

assent or agree to the doing of an act’’). 

22 Garner’s Dictionary of Legal Usage 46 (3d ed. 

2011); see also Alexander v. Carrington Mortgage 

Services, 23 F.4th 370, 377 (4th Cir. 2022) (holding 

‘‘permitted by law’’ requires affirmative 

authorization). 

23King v. Burwell, 576 U.S. 473, 492 (2015). 24Note that, even if pay-to-pay fees are expressly 

authorized in the underlying agreement or 

permitted by State law, debt collectors must still 

take care to comply with other laws, including 

other provisions of the FDCPA and the Consumer 

Financial Protection Act’s prohibition on unfair, 

deceptive, or abusive acts or practices, when 

assessing pay-to-pay fees. 25The CFPB acknowledges that some district 

courts have held otherwise. See, e.g., ThomasLawson v. Carrington Mortg. Servs., LLC, No. 2:20– 

cv–07301–ODW, 2021 WL 1253578 (C.D. Cal. Apr. 

5, 2021), appeal pending, No. 21–55459 (9th Cir.). 26See Obduskey v. McCarthy & Holthus LLP, 139 

S. Ct. 1029, 1037 (2019) (refusing to interpret the 

B. Coverage 

This advisory opinion applies to debt 

collectors as defined in section 803(6) of 

the FDCPA and implemented in 

Regulation F, 12 CFR 1006.2(i). As used 

in this advisory opinion, pay-to-pay 

fees—sometimes called convenience 

fees—refers to fees incurred by 

consumers to make debt collection 

payments through a particular channel, 

such as over the telephone or online. 

C. Legal Analysis 

1. Any Amount 

Section 808(1) of the FDCPA prohibits 

debt collectors, in relevant part, from 

‘‘collect[ing] . . . any amount (including 

any interest, fee, charge, or expense 

incidental to the principal 

obligation).’’ 14 As the Supreme Court 

has explained, the ‘‘word ‘any’ has an 

expansive meaning, that is, ‘one or some 

indiscriminately of whatever kind.’ ’’ 15

In addition, under its ordinary meaning, 

the term ‘‘including’’ typically indicates 

a partial list.16 The CFPB interprets the 

words ‘‘any’’ and ‘‘including’’ as used in 

section 808(1) consistent with their 

ordinary meanings. Accordingly, the 

CFPB clarifies that FDCPA section 

808(1) and Regulation F, 12 CFR 

1006.22(b), apply to any amount 

collected by a debt collector in 

connection with the collection of a 

debt,17 including, but not limited to, any 

interest, fee, charge, or expense that is 

incidental to the principal obligation. 

Consistent with this interpretation, 

the CFPB further clarifies that pay-topay fees charged to consumers for 

accepting a consumer’s payment on a 

debt through a particular payment 

channel are an ‘‘amount’’ within the 

meaning of FDCPA section 808(1) and 

Regulation F, 12 CFR 1006.22(b). The 

CFPB acknowledges that some courts 

have held otherwise, finding that payto-pay fees do not violate FDCPA 

section 808(1) because such fees are not 

‘‘incidental to the principal 

obligation.’’ 18 But, as explained, the 

CFPB interprets section 808(1) to apply 

to ‘‘any amount,’’ even if such amount 

is not ‘‘incidental to’’ the principal 

obligation.19

2. Permitted by Law 

Section 808(1) of the FDCPA 

prohibits, in relevant part, the collection 

of any amount ‘‘unless such amount is 

expressly authorized by the agreement 

creating the debt or permitted by 

law.’’ 20 The word ‘‘permit’’ is 

susceptible to multiple meanings, but it 

tends to refer to ‘‘affirmative 

authorization,’’ and the CFPB reads 

section 808(1) to use the word in that 

sense. Dictionaries provide that 

‘‘permit’’ can mean either ‘‘to consent to 

expressly or formally,’’ suggesting 

affirmative authorization, or to ‘‘allow’’ 

or ‘‘to acquiesce, by failure to prevent,’’ 

suggesting that the lack of a prohibition 

is sufficient.21 However, ‘‘allow and 

permit have an important connotative 

difference. Allow . . . suggests merely 

the absence of opposition, or refraining 

from a proscription. In contrast, permit 

suggests affirmative sanction or 

approval.’’ 22 Use of the word ‘‘permit,’’ 

rather than ‘‘allow,’’ therefore suggests 

that affirmative authorization, rather 

than a mere lack of a prohibition, is 

required. Furthermore, as the Supreme 

Court has instructed, ‘‘words of a statute 

must be read in their context,’’ 23 and 

here, ‘‘permit’’ is used not in isolation 

but as part of the phrase ‘‘permitted by 

law.’’ While in some contexts one may 

‘‘permit’’ something by failing to 

prevent it, it is far less natural to 

understand ‘‘permitted by law’’ to mean 

‘‘permitted by the absence of any law 

prohibiting it.’’ 

The CFPB therefore interprets FDCPA 

section 808(1) to prohibit a debt 

collector from collecting any amount 

unless such amount either is expressly 

authorized by the agreement creating 

the debt (and is not prohibited by law) 

or is expressly permitted by law. That 

is, the CFPB interprets FDCPA section 

808(1) to permit collection of an amount 

only if: (1) the agreement creating the 

debt expressly permits the charge and 

some law does not prohibit it; or (2) 

some law expressly permits the charge, 

even if the agreement creating the debt 

is silent. The CFPB’s interpretation of 

the phrase ‘‘permitted by law’’ applies 

to any ‘‘amount’’ covered under section 

808(1), including pay-to-pay fees.24

Under the CFPB’s interpretation, an 

amount is impermissible if both the 

agreement creating the debt and other 

law are silent. For example, under the 

CFPB’s interpretation, amounts, 

including pay-to-pay fees, that are 

neither expressly authorized by the 

agreement creating the debt nor 

expressly authorized by law are 

impermissible under FDCPA section 

808(1) and Regulation F, 12 CFR 

1006.22(b), even if such amounts are the 

subject of a separate, valid agreement 

under State contract law.25 Although 

some courts have adopted this ‘‘separate 

agreement’’ interpretation to permit debt 

collectors to collect, for example, certain 

pay-to-pay fees, the CFPB declines to do 

so. Such a reading would render the 

part of section 808(1) that refers to 

amounts ‘‘expressly authorized by the 

agreement creating the debt’’ 

superfluous 26 because a lawful 


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Federal Register / Vol. 87, No. 127 / Tuesday, July 5, 2022 / Rules and Regulations 39735 

FDCPA in a way that would render a provision 

‘‘superfluous’’). 

27Accord Alexander, 23 F.4th at 379 (rejecting 

the separate agreement interpretation in part 

because it would render section 808(1)’s other 

prong superfluous). The separate agreement 

interpretation also would conflict with the FDCPA’s 

use of the phrase ‘‘expressly authorized,’’ since 

general principles of State contract law allow 

parties to agree to express or implied terms as part 

of any agreement. See Restatement (Second) of 

Contracts § 4 cmt. a (1981). If general principles of 

contract law counted as a ‘‘law’’ that ‘‘permitted’’ 

the collection of amounts, debt collectors would be 

free to collect not only those amounts authorized 

by separate agreements, but also to collect amounts 

that are only implicitly authorized by the agreement 

creating the debt—further rendering section 808(1)’s 

‘‘express’’ requirement meaningless. 

28See Johnson v. Riddle, 305 F.3d 1107, 1118 

(10th Cir. 2002) (‘‘The statute does not ask whether 

[the debt collector’s] actions were permitted by law 

. . . , it asks whether the amount he sought to 

collect was permitted by law.’’ (emphasis in 

original)). 

29While a contract might, consistent with 

contract law, permit an amount, section 808(1) only 

permits collecting amounts authorized by contract 

when the amount is expressly authorized by the 

contract ‘‘creating the debt.’’ 

30See, e.g., Alexander, 23 F.4th at 376–77 

(holding, in a case regarding pay-to-pay fees, that 

‘‘ ’permitted by law’ requires affirmative sanction or 

approval’’); Seeger v. AFNI, Inc., 548 F.3d 1107, 

1111, 1112 (7th Cir. 2008) (finding that, to be 

entitled to collect a fee, debt collectors ‘‘must show 

that the fee is either authorized by the governing 

contract or that it is permitted by Wisconsin law’’ 

and that, in that case, that neither an agreement nor 

a law expressly permitting a collection fee existed); 

Tuttle v. Equifax Check, 190 F.3d 9, 13 (2d Cir. 

1999) (explaining that if ‘‘state law neither 

affirmatively permits nor expressly prohibits 

service charges, a service charge can be imposed 

only if the customer expressly agrees to it in the 

[underlying] contract’’). 

31See Staff Commentary on the Fair Debt 

Collection Practices Act, 53 FR 50097, 50101 (Dec. 

13, 1988). 32 Id. at 50108. 33 Id. 34See, e.g., Ballentine’s Law Dictionary (3d ed. 

2010) (defining ‘‘collect’’ as ‘‘to receive payment’’); 

cf. 15 U.S.C. 1692a(6) (defining debt collector to 

include persons who ‘‘directly or indirectly’’ collect 

debts). 

35 12 U.S.C. 5512(b)(1); 5481(14); 5481(12)(H). 

36 5 U.S.C. 553(b). 

37 5 U.S.C. 603(a), 604(a). 

38 44 U.S.C. 3501–3521. 

39 5 U.S.C. 801 et seq. 

agreement creating the debt is, by 

definition, an agreement valid under 

State contract law.27 In addition, the 

separate agreement interpretation 

ignores section 808(1)’s focus on the 

‘‘amount’’ being ‘‘expressly authorized 

by the agreement creating the debt’’ or 

‘‘permitted by law.’’ 28 Under section 

808(1), it is not enough for the 

agreement to be ‘‘permitted by law’’; 

rather, the ‘‘amount’’ itself must be. 

Contract law standing alone does not 

provide for the collection of any specific 

amounts—and no principle of contract 

law says debt collectors may collect 

pay-to-pay fees.29 Thus, while it may 

have been permissible under contract 

law for a debt collector to enter into 

separate agreements with consumers, 

contract law does not permit the 

‘‘amount’’ at issue, i.e., the pay-to-pay 

fees. 

The CFPB’s interpretation of 

‘‘permitted by law’’ in FDCPA section 

808(1) is consistent with the previous 

interpretation in a CFPB compliance 

bulletin as discussed in part I.A., as well 

as with the prior interpretation of FTC 

staff and the holdings of the majority of 

courts to address the issue.30 In 

particular, in 1988, FTC staff issued 

Commentary that set forth ‘‘staff 

interpretations’’ of the FDCPA.31 As 

relevant here, FTC staff stated that, 

under section 808(1), a ‘‘debt collector 

may attempt to collect a fee or charge in 

addition to the debt if . . . the contract 

[creating the debt] is silent but the 

charge is otherwise expressly permitted 

by state law.’’ 32 Conversely, FTC staff 

stated that ‘‘a debt collector may not 

collect an additional amount if . . . the 

contract does not provide for collection 

of the amount and state law is silent.’’ 33

The CFPB’s interpretation is also 

consistent with the FDCPA’s statutory 

purposes. As noted in part I.A, Congress 

passed the FDCPA because it found that 

existing laws and procedures, including 

at the state level, were inadequate to 

protect consumers. Given this concern, 

it would be particularly unnatural to 

understand ‘‘permitted by law’’ to mean 

‘‘permitted because no law prohibits it.’’ 

Accordingly, the CFPB interprets 

FDCPA section 808(1) and Regulation F, 

12 CFR 1006.22(b), to prohibit debt 

collectors from collecting any amount, 

including any pay-to-pay fee, not 

expressly authorized in the agreement 

creating the debt unless there is some 

law that affirmatively authorizes the 

collection of that amount. 

3. Payment Processors 

Debt collectors may violate FDCPA 

section 808(1) and Regulation F, 12 CFR 

1006.22(b), when using payment 

processors who charge consumers payto-pay fees. For instance, a debt 

collector collects an amount under 

section 808(1) at a minimum when a 

third-party payment processor collects a 

pay-to-pay fee from a consumer and 

remits to the debt collector any amount 

in connection with that fee, whether in 

installments or in a lump sum.34

II. Regulatory Matters 

This is an advisory opinion issued 

under the CFPB’s authority to interpret 

the FDCPA, including under section 

1022(b)(1) of the Consumer Financial 

Protection Act, which authorizes 

guidance as may be necessary or 

appropriate to enable the CFPB to 

administer and carry out the purposes 

and objectives of Federal consumer 

financial laws, such as the FDCPA.35

An advisory opinion is a type of 

interpretive rule. As an interpretive 

rule, this advisory opinion is exempt 

from the notice-and-comment 

rulemaking requirements of the 

Administrative Procedure Act.36

Because no notice of proposed 

rulemaking is required, the Regulatory 

Flexibility Act does not require an 

initial or final regulatory flexibility 

analysis.37 The CFPB has also 

determined that this advisory opinion 

does not impose any new or revise any 

existing recordkeeping, reporting, or 

disclosure requirements on covered 

entities or members of the public that 

would be collections of information 

requiring approval by the Office of 

Management and Budget under the 

Paperwork Reduction Act.38

Pursuant to the Congressional Review 

Act,39 the CFPB will submit a report 

containing this advisory opinion and 

other required information to the United 

States Senate, the United States House 

of Representatives, and the Comptroller 

General of the United States prior to the 

opinion’s published effective date. The 

Office of Information and Regulatory 

Affairs has designated this advisory 

opinion as not a ‘‘major rule’’ as defined 

by 5 U.S.C. 804(2). 

Rohit Chopra, 

Director, Consumer Financial Protection 

Bureau. 

[FR Doc. 2022–14230 Filed 7–1–22; 8:45 am] 

BILLING CODE 4810–AM–P 

DEPARTMENT OF TRANSPORTATION 

Federal Aviation Administration 

14 CFR Part 39 

[Docket No. FAA–2022–0382; Project 

Identifier MCAI–2021–01452–T; Amendment 

39–22099; AD 2022–13–13] 

RIN 2120–AA64 

Airworthiness Directives; Airbus SAS 

Airplanes 

AGENCY: Federal Aviation 

Administration (FAA), Department of 

Transportation (DOT). 

ACTION: Final rule. 

SUMMARY: The FAA is adopting a new 

airworthiness directive (AD) for all 

Airbus SAS Model A350–941 and –1041 

airplanes. This AD was prompted by 

reports that passenger door stop screws 

were found with missing screw heads. 


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