Reg F Question of the Week: What is Defined as an Inconvenient or Unusual Time?

FAQThe CFPB updated its FAQs on the Reg F debt collection rule, including information about electronic communications, limited-content messages, and more. ACA will regularly feature updates on the FAQs when available from the CFPB.

03/23/2023 2:00 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 telephone call frequency.

Q. What does the debt collection rule define as an inconvenient or unusual time?

A. In the absence of the debt collector’s knowledge of circumstances to the contrary, an inconvenient time for communicating with a consumer is before 8 a.m. and after 9 p.m. local time at the consumer’s location.

If a debt collector has conflicting or ambiguous information regarding a consumer’s location, the debt collector complies if the debt collector communicates or attempts to communicate with the consumer at a time that would be convenient in all of the locations at which the debt collector’s information indicates the consumer might be located. Comment 6(b)(1)(i)-2.

For purposes of determining the time of an electronic communication, an electronic communication or electronic attempt to communicate occurs at the time that the debt collector sends it, not, for example, at the time that the consumer receives or views it. Comment 6(b)(1)(i)-1.

For more information on the prohibition on communicating at unusual or inconvenient times or places, see Debt Collection Unusual or Inconvenient Times or Places Questions 1 and 3 and Section 4.1 in the Debt Collection Small Entity Compliance Guide . For more information on the exception to this prohibition, see Debt Collection Unusual or Inconvenient Times or Places Question 5 and Section 4.4 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: Are Certain Calls Excluded From the Presumptions of Telephone Call Frequency?

Reg F Question of the Week: Is a Limited-Content Message Excluded from the Presumptions of Telephone Call Frequency?

Is Use of the Model Validation Notice Required?

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