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CFPB Debt Collection Rule FAQs (Compliance Aid)

Effective 2022-07-27 · Verified 2026-07-03

Authority

CFPB-published FAQs interpreting Regulation F (12 CFR part 1006) — a compliance aid, not a rule. The controlling text is Regulation F itself (see the ../reg-f/ pages); these FAQs are the Bureau's official reading of how the rule applies. Page live and unchanged banner-free as of 2026-07-03; the FAQs were NOT among the debt-collection items in the CFPB's May 2025 guidance withdrawal (90 FR 20084), which named the three debt-collection advisory opinions and two bulletins. First FAQ tranche published Oct 29, 2021; electronic-communication/timing FAQs added July 27, 2022 (dates per the CFPB debt-collection compliance-resources page).

All Q/A quotes below are verbatim from the FAQ page (ellipses mark omitted text): https://www.consumerfinance.gov/compliance/compliance-resources/other-applicable-requirements/debt-collection/debt-collection-rule-faqs/

Operative text — the FAQs an agency lives by

Limited-content messages

Q: What is a "limited-content message"? A: …a message that: Is a voicemail; Is for a consumer; and Includes the required content… [including] A business name for the debt collector that does not indicate that the caller is in the business of collecting debts — Debt Collection Rule FAQs, Limited-Content Messages (interpreting 12 CFR 1006.2(j))

Q: Is a limited-content message a "communication"? A: No. Under the Debt Collection Rule…a limited-content message is an "attempt to communicate" but is not a "communication" — Debt Collection Rule FAQs, Limited-Content Messages

Further FAQ points (same section, paraphrase — see page for full text): a limited-content message is voicemail only; a dropped/partial voicemail that lacks required content is not a limited-content message; adding any content beyond the rule's required + optional items (including the old "Zortman" phrasing "call from a debt collector") destroys limited-content status; the business name used need not be the legal/DBA name, but must not indicate debt collection even if a web search would identify the caller.

Telephone call frequency

Q: What are the presumptions related to telephone call frequency? A: …presumed to comply…if the debt collector places a telephone call…neither: More than seven times within seven consecutive calendar days [nor within seven consecutive calendar days after having had a telephone conversation about the debt] …presumed to violate…if the debt collector places a telephone call…More than seven times within seven consecutive calendar days — Debt Collection Rule FAQs, Telephone Call Frequency (interpreting 12 CFR 1006.14(b)); bracketed text summarizes the second prong — controlling text at ../reg-f/call-frequency.md

Further FAQ points (same section, paraphrase): counting is per person, per debt (not per phone number); consumer-initiated inbound calls don't count (but a conversation starts the 7-day post-conversation clock); the 7-in-7 presumptions cover telephone calls only — texts/emails are outside 1006.14(b) but count toward general harassment analysis under 1006.14(a); misdirected calls count against the actual recipient's tally, not the intended consumer's; a call discussing multiple debts is a conversation "about" each debt; unanswered calls spanning multiple debts may be allocated among them; excluded calls = direct prior consent (valid max 7 days, revocable), calls that do not connect (busy signal / not-in-service — but ringing-unanswered and voicemail DO connect and count), and calls to attorney/creditor/CRA-type permitted parties; presumptions are rebuttable both ways (e.g., a required-by-law or time-critical call can rebut violation; abusive pattern can rebut compliance); state laws with stricter frequency limits are not preempted.

Electronic communications

[Timing] …an electronic communication or electronic attempt to communicate occurs at the time that the debt collector sends it — Debt Collection Rule FAQs, electronic communications/timing FAQs (added July 27, 2022; interpreting 12 CFR 1006.6(b)(1) — the 8:00 a.m.–9:00 p.m. consumer-local-time window; controlling text at ../reg-f/electronic-communications.md)

Further FAQ points (paraphrase): nothing in the rule requires electronic communication, but choosing it pulls in the full stack — harassment/deception prohibitions, the ban on work-email and public-facing social media contact, unusual times/places, cease-communication and per-medium opt-outs, required disclosures, and third-party prohibitions (which apply fully to electronic channels); if the consumer's location is ambiguous, sending at a time compliant in all plausible locations satisfies the rule.

Opt-out notice (every electronic communication)

Q: What is the Debt Collection Rule's opt-out notice requirement for electronic communications? A: …include a clear and conspicuous opt-out notice in all electronic communications…describe a reasonable and simple method by which the consumer can opt out — Debt Collection Rule FAQs, Electronic Communication: Opt-out Notice (interpreting 12 CFR 1006.6(e))

Further FAQ points (paraphrase): opt-out is tracked per email address / per phone number / per medium; "reasonable and simple" = reply STOP, an unsubscribe hyperlink, or similar — requiring postal mail, a phone call, or visiting an unlinked website does NOT qualify; the collector must honor opt-out language that ignores the stated instructions ("stop", "unsubscribe", "end", "quit", "cancel" all count); one electronic confirmation of the opt-out may be sent; if the consumer later initiates contact on an opted-out medium the collector may respond once.

Validation information

Further FAQ points (paraphrase; see ../reg-f/validation-notice.md for the controlling content requirements): the model validation notice in Appendix B of the rule is optional — the rule requires the content/format, the model is one safe-harbor way to comply; limited modifications preserve the safe harbor (optional-content changes, rule-specified changes, or "substantially similar" results); a special rule lets mortgage debt collectors substitute a Regulation Z periodic statement for the itemization-related information.

Plain English

(Interpretation — quotes and Regulation F win on any conflict.)

These FAQs are where the CFPB answers the operational questions Reg F's text leaves ambiguous: what exactly a voicemail may say and still not be a "communication," how the 7-in-7 presumption counts across numbers/debts/media, when an email is "sent" for the time-window rule, and what an opt-out link must look like. They are the closest thing to an official spec for building dialer and messaging behavior. They bind no one, but examiners use them.

Traps / edge cases

  • Limited-content = voicemail only. There is no limited-content text message or email under the rule, per the FAQ definition.
  • 7-in-7 is per debt. A consumer with 3 placed debts can lawfully receive more than 7 calls/week in aggregate — but the harassment backstop (1006.14(a)) still applies to the aggregate pattern, including across media.
  • Voicemail counts. A connected call that reaches voicemail (including a limited-content message) counts toward frequency; only busy/not-in-service calls are "not connected."
  • Opt-out scope is per address, not per person. Opting out one email address does not opt out the consumer's other addresses — but track cease-communication requests (1006.6(c)) separately; those are per consumer.
  • Send-time, not receipt-time, controls the 8 a.m.–9 p.m. electronic window.

CFPB Debt Collection Rule compliance resources (verified live 2026-07-03)

Resource Date shown URL
Debt Collection Rule FAQs Oct 29, 2021; electronic-comms tranche July 27, 2022 https://www.consumerfinance.gov/compliance/compliance-resources/other-applicable-requirements/debt-collection/debt-collection-rule-faqs/
Small Entity Compliance Guide (v2.0) version 2.0 (no date on page) https://files.consumerfinance.gov/f/documents/cfpb_debt-collection_small-entity-compliance-guide.pdf
Model validation notice — English (PDF) modified Mar 12, 2025 https://files.consumerfinance.gov/f/documents/cfpb_debt-collection_model-validation-notice_english.pdf
Model validation notice — Spanish (PDF) Oct 18, 2021; modified Mar 12, 2025 https://files.consumerfinance.gov/f/documents/cfpb_debt-collection_model-validation-notice_spanish.pdf
Editable validation-notice forms (CFPB GitHub) https://github.com/cfpb/debt-collection-files
"Disclosing the Model Validation Notice Itemization Table" Oct 29, 2021 https://files.consumerfinance.gov/f/documents/cfpb_debt-collection_disclosing-the-MVN-itemization-table.pdf
Executive summary — December 2020 final rule Dec 2020 https://files.consumerfinance.gov/f/documents/cfpb_december_2020_debt_collection_executive_summary.pdf
Executive summary — October 2020 final rule Oct 2020 https://files.consumerfinance.gov/f/documents/cfpb_october_2020_debt_collection_executive_summary.pdf
FDCPA examination procedures https://www.consumerfinance.gov/compliance/supervision-examinations/fair-debt-collection-practices-act-fdcpa-examination-procedures/
Debt collection examination procedures https://www.consumerfinance.gov/compliance/supervision-examinations/debt-collection-examination-procedures/

Related

  • ../reg-f/limited-content-message.md — controlling text, 12 CFR 1006.2(j)
  • ../reg-f/call-frequency.md — controlling text, 12 CFR 1006.14(b)
  • ../reg-f/electronic-communications.md — controlling text, 12 CFR 1006.6
  • ../reg-f/validation-notice.md — controlling text, 12 CFR 1006.34
  • ../fdcpa/unfair-practices.md
  • ./overview.md

Official sources on file

This page cites

Compiled from official sources only, with the operative text quoted verbatim. This is information, not legal advice — check it against the source before you act on it.