The CFPB recently updated its FAQs on the Reg F debt collection rule, including information about limited-content messages, electronic communication, and more. ACA will regularly feature updates on the FAQs when available from the CFPB.
02/24/2023 1:45 P.M.
2 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 electronic communications, limited-content messages, telephone call frequency and more.
ACA International regularly highlights the bureau’s updates to the FAQs. Read on to learn about guidelines related to limited-content messages.
Q. Is a limited-content message excluded from the presumptions of telephone call frequency?
A. No. There is no specific exclusion from the telephone call frequencies in the debt collection rule for limited-content messages.
A telephone call counts toward the telephone call frequencies if it connects to a dialed number, unless the call is otherwise excluded as discussed in Debt Collection Telephone Call Frequency: Excluded Calls Question 1. If a debt collector’s telephone call is connected to a voicemail or other recorded message, it is considered connected. Comment 14(b)(3)(ii)-1.
The rule defines a limited-content message as a voicemail message for a consumer that contains specified required content and that may also contain certain optional content as described in Debt Collection Limited-Content Messages Question 1. Since a limited-content message is a voicemail message, it is considered a connected call. For additional examples of calls that are considered connected or not connected to a dialed number, see Debt Collection Telephone Call Frequency: Excluded Calls Question 3.
For more information about the prohibition against repeated or continuous telephone calls or conversations, see Section 7 in the Debt Collection Small Entity Compliance Guide . For more information about the presumptions related to telephone call frequency, see Debt Collection Telephone Call Frequency: Presumptions Question 1. For more information about calls that are excluded from the telephone call frequencies, see Debt Collection Telephone Call Frequency: Excluded Calls Question 1 and 3.
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