Insights Needed: How is Your Agency Preparing for Call Frequency Requirements Under Reg F?


Agencies are asked to share their feedback and input on the seven-in-seven rule when it comes to collection calls. Editor’s note: This article is available for members only.

9/6/2021 9:00

As the compliance date for the Consumer Financial Protection Bureau’s Reg F approaches, ACA International wants to know how members are preparing to comply with the call frequency requirements.

In one of the higher impact provisions of the final rule, the bureau finalized its proposed provision on call-frequency limitations, but with two twists:  

  • First, rather than a bright-line calling limitation, as proposed, the call-frequency provision in the final rule creates a rebuttable presumption, ACA’s Corporate Counsel Colin Winkler reported in Collector magazine.
  • Second, rather than apply the call-frequency limitations to a specific consumer, the rule applies them to calls placed “to a particular person in connection with the collection of a particular debt…” (Emphasis added.) ­

In terms of operations, the call-frequency limitations generally require that a debt collector not place a telephone call “to a particular person” (which is broader than just “to the consumer”):

  • More than seven times in a period of seven consecutive days; or
  • Within seven consecutive days after having had a conversation with that person via telephone. Certain calls do not count for the purposes of the rule. If you call a person within seven days of receiving her consent to call, that doesn’t count.

ACA is seeking information from first-party collection agencies on their approach to compliance with the call-frequency requirements.

  • In some cases, companies might already be below these limits. ACA also welcomes feedback from these companies about whether they be managing their call frequency limits to comply with the rule.
  • Even though Reg F doesn’t technically apply to first-party collection agencies, we would like to know how those companies are managing their call-frequency limits given potential application of the rule in the future.
  • For those companies that are adjusting their first-party practices, ACA seeks feedback on if they will adopt the “seven in seven” rule; if it will apply it in all states where they are licensed or just some states; and the timing and approach to the change.

ACA is also specifically interested in whether agencies will adjust their calling frequency to comply.

Please share your input by emailing Leah Dempsey, vice president and senior counsel, federal advocacy, at [email protected] by Sept. 12.

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