Reg F Question of the Week: Are There Requirements for Electronic Communications?

The CFPB recently updated its FAQs on the Reg F debt collection rule, including information about prohibitions on third-party communications and exceptions to those prohibitions. ACA will regularly feature updates on the FAQs when available from the CFPB.

09/21/2022 10:45 A.M.

1.5 minute read

The Consumer Financial Protection Bureau has published Debt Collection Rule FAQs for Regulation F, containing questions and answers that pertain to compliance with the rule. The FAQs cover limited-content messages and call frequency issues, and most recently featured updates on electronic communications requirements

ACA International regularly highlights the bureau’s updates to the FAQs. Read on to learn about exceptions to prohibitions on third-party communications updated on July 27, 2022.

1. Does the debt collection rule require debt collectors to communicate electronically with consumers?
2. No. Nothing in the Debt Collection Rule requires a debt collector to communicate with consumers electronically. For example, absent additional facts, if a consumer sends a debt collector a text message, nothing in the Debt Collection Rule requires the debt collector to reply with a text message. If a debt collector chooses to communicate with consumers electronically there are several provisions in the debt collection rule that apply, such as the prohibition on using an employer provided email address or contacting consumers through a social media platform if the communicate or attempt to communicate is viewable by the public or the consumer’s contacts.

The CFPB also notes the general prohibition on third-party communications covered last month by ACA applies to electronic communications from a debt collector about a debt. For more information on the prohibition against third-party communications, see section six in the Debt Collection Small Entity Compliance Guide.

Read the CFPB’s complete debt collection rule FAQs here.

Related Content from ACA International:

Reg F Question of the Week: Prohibitions on Third-Party Communications?

Reg F Question of the Week: What are the Exceptions to Prohibitions on Third-Party Communications?

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