Comment on CFPB-2012-0005-0003

I am not a lobbyist and my statements are not those of any other person, including my firm. I act as legal counsel that offers primarily commercial and agricultural debt collection and a very small amount of consumer debt collection. I have the following comments: (1) I would suggest adding professional corporations and professional limited liability companies to the definition of "Company." (2) I would suggest that the "related to" portion of the definition of "Consumer debt collection" is too broad and vague. I often collect debts that are primarily commercial, agricultural or industrial debts but occassionally have some other consumer related debt that is a minor part of a collection of multiple categories of debt from the same person. The current language is broad enough to arguably recharacterize commercial debt collection efforts as consumer debt collection if you have two loans that are somewhat interrelated, even if the consumer debt is a fraction of the value of the commercial debt. This issue would cause very small participants in the consumer collection arena to appear larger because the commercial or other debt collection is not adequately segregated from the consumer debt collection efforts. I would prefer you clarify the definition for consumer debt collection by changing the phrase "any debt owed" to "that portion of any debt owed." This would make it more clear that only the collection of consumer financial product and service receipts and associated fees go into the calculation, and not the commercial, industrial or agricultural debt. Alternatively, you could consider using the language "or due to another and arising out of any consumer financial product or service" rather than the "related to" language.