No local layer — localities checked with no debt-collection regime of their own

This page is a negative-coverage record, not an authority. It exists so that an agent surface or tool can answer "does Atlanta add anything on top of Georgia?" with a sourced no and a date, instead of the "no page covers this" decline that _meta/protocol.md rule 12 otherwise requires. A sourced no is an answer; silence is not.

How to use this page

1. A locality listed below adds nothing as of the checked date. Answer from the state page (state/_matrix.md → the relevant state), plus federal.
2. A locality NOT listed below has not been checked. That is a decline, not a clear. Say so.
3. A locality in the "Open" section has been looked at and not resolved. Also a decline, but say which way the evidence leans and why it is unresolved.
4. Localities that do add a layer have their own pages — see Related and the Local / municipal table in INDEX.md.

⚠ This records a state of the world on one date. Municipal law moves without the notice infrastructure state law has. This page is treated as stale after 90 days; re-running the sweep is cheap (§ Method) and should be scheduled, not left to drift.

What was being looked for

A locality counts as having "a layer" if it does any of these specifically to debt collection:

• licenses or registers collectors, or charges them a collection-specific fee;
• imposes conduct, disclosure or dispute rules on collectors;
• binds collectors by ordinance, rule or executive order.

Deliberately not counted as a layer:

• a general business licence every business needs (Philadelphia's Commercial Activity License, San Francisco's business registration, Wilmington's per-branch business licence);
• the locality hiring a collection agency for its own receivables — by a wide margin the most common false positive, and the reason a raw keyword count is not a finding;
• refuse collection, tax collection, and other "collection" homonyms.

Method

Every locality was checked on 2026-08-21.

Municode full-text ("Municode FT") — the locality's official codified ordinances searched for the quoted phrases "collection agency" and, for the largest metros, "debt collector", with every hit read rather than counted. Client IDs come from the publisher's open API (api.municode.com/Clients/stateAbbr?stateAbbr=<XX>), and a search is addressable directly:

https://library.municode.com/search?stateId=<SID>&clientId=<CID>&searchText=<urlencoded>&searchMode=CLIENTMODE&contentTypeId=CODES

The page is an Angular SPA, so it needs a real browser; the hit count parses off Showing results 1 to N of M, and each hit exposes a stable ?nodeId= deep link. This is what makes these negatives auditable rather than assertions.

Catalogue — for localities not on Municode, the locality's own official business licence/permit catalogue, read for a collection-agency category.

Known limits of the method, stated so the negatives are not over-read:

• It is phrase-based. A locality regulating collectors in wording that avoids both "collection agency" and "debt collector" would be missed.
• It covers the largest ~60 metros plus the localities a national industry compilation flagged. Small and mid-size cities are not covered.
• It does not cover local court rules for consumer-debt litigation (default-judgment affidavits, pleading attachments). Those change what a collector must file, not what it must do, and are invisible to a code search. Separate research axis.
• A "0 results" reading was confirmed against the search UI's own Showing results 1 to 0 of 0, not inferred from a blank page.

Cleared — no locality-specific debt-collection regime

Locality	Method	What was found
Boston, MA	Municode FT ×2 terms	0 / 0
Philadelphia, PA	Catalogue (L&I)	No collection category; the Commercial Activity License is universal and free
San Francisco, CA	Catalogue (Treasurer & Tax Collector)	No collection category among the regulatory "P"/"H"/"D" licences
Baltimore City, MD	Catalogue	No collection category
Cleveland, OH	Catalogue (Assessments & Licenses)	No collection category
Portland, OR	Official Title 7 (Business Licenses) full text	1 incidental hit (a towing operator's disclosure)
Seattle, WA	Municode FT ×2 terms	44 / 0 — all city-as-creditor
Denver, CO	Municode FT ×2 terms	1 / 0 — incidental
Cook County, IL	Municode FT ×2 terms	0 / 1 — the "debt collector" hit is an employment provision
Houston, TX	Municode FT ×2 terms	2 / 0 — incidental
Austin, TX	Municode FT	0
San Antonio, TX	Municode FT	2 — incidental
Atlanta, GA	Municode FT ×2 terms	1 / 0 — enforcement provision
Detroit, MI	Municode FT ×2 terms	0 / 0
Minneapolis, MN	Municode FT ×2 terms	1 / 0 — animal impound
St. Paul, MN	Municode FT	2 — city-as-creditor
Kansas City, MO	Municode FT	2 — incidental
St. Louis, MO	Municode FT	4 — incidental
Miami-Dade County, FL	Municode FT ×2 terms	1 / 0 — civil penalty schedule
Broward County, FL	Municode FT	1 — "Use of Collection Agencies" (county as creditor)
Jacksonville, FL	Municode FT	13 — all ch. 112, the city's own collection-agency contracting rules
Tampa, FL	Municode FT	1 — parking enforcement
Orlando, FL	Municode FT	0
Memphis, TN	Municode FT	1 — definitions, incidental
Nashville–Davidson, TN	Municode FT	0
Charlotte, NC	Municode FT	1 — legacy licence-tax schedule
Raleigh, NC	Municode FT	1 — administrative fees
Baltimore County, MD	Municode FT	0
Prince George's County, MD	Municode FT ×2 terms	0 / 0
Montgomery County, MD	Official OCP materials	Ch. 11 is general UDAP; collector licensing is state-level (MD Dept. of Labor / MCALA)
Cincinnati, OH	Municode FT	0
Columbus, OH	Municode FT	1 — definitions, incidental
Akron, OH	Municode FT	1 — definitions, incidental
Dayton, OH	Municode FT	1 — city authorising its own collection agents
Las Vegas, NV	Municode FT	9 — all city-as-creditor. ⚠ Clark County is different — see Related
Reno, NV	Municode FT	0
Indianapolis–Marion County, IN	Municode FT	0
New Orleans, LA	Municode FT	7 — the city's outside-collector authorisation and utility billing
Oklahoma City, OK	Municode FT	1 — court costs
Omaha, NE	Municode FT	1 — motor-vehicle registration, unrelated
Fairfax County, VA	Municode FT	3 — licence-tax penalties
Richmond, VA	Municode FT	3 — refuse collection
Virginia Beach, VA	Municode FT	2 — refuse collection
Norfolk, VA	Municode FT	4 — refuse / library fees
Los Angeles County, CA	Municode FT ×2 terms	0 / 0 for licensing. ⚠ LA County does have a medical-debt reporting ordinance in Title 11 — see Open
San Jose, CA	Municode FT	0
Oakland, CA	Municode FT	0
Birmingham, AL	Municode FT	0
Charleston, SC	Municode FT	0
Madison, WI	Municode FT	0
Des Moines, IA	Municode FT	0
Syracuse, NY	Municode FT	1 — city-as-creditor
Hartford, CT	Municode FT	0
Jersey City, NJ	Municode FT	0
Nassau County, NY	Catalogue (Consumer Affairs)	11 licensed trades under the County Administrative Code; collection agencies not among them
Suffolk County, NY	Catalogue (Consumer Affairs)	No collection-agency licence
Wilmington, DE	Municode FT + code inspection	General business licence only — see the correction below
Milwaukee, WI	Official code index + ch. 81 fee schedule + Common Council legislative record (checked 2026-08-22)	0 collection-agency provisions; the code's only Collector's license is the waste collector at § 81-133 — see the correction below

⚠ Wilmington, DE — a widely repeated error

A national industry compilation (Moss & Barnett / AFSA, 2020) lists "Wilmington, Del. Code § 5-52" as requiring collection agencies to license branch locations, and that citation circulates.

It is wrong. Checked against the current Wilmington City Code (Municode, Version: Jul 27, 2026 (current), codified through Ordinance No. 25-073 enacted 2025-12-11): § 5-52 is "License for branch establishments," a provision of the general business-licence article that applies to every licensed business in the city. Nothing in it is specific to collection. A full-text search for "collection agency" returns 32 hits, exactly one of which falls in ch. 5 (Businesses) — § 5-101, the general schedule of licence fees.

Wilmington collectors owe the ordinary business licence, per branch, like any other service business. Recorded here because someone will eventually re-find the compilation and ask.

Correction — Milwaukee's "Collector's license" is a waste hauler

Milwaukee was carried as unknown in the first pass because city.milwaukee.gov returns HTTP 403 to automated fetch. It resolved clear on 2026-08-22, and the way it resolved is worth recording, because the obvious search gives the wrong answer.

A general web search for Milwaukee collection-agency licensing reports that ch. 81 covers it. It does not. The city's own index to the Charter and Code of Ordinances (ImageLibrary/Groups/ccClerk/Ordinances/Volume-3/v3index.pdf) carries exactly one Collector's license entry, at § 81-133 — Waste Collector's License, Private, indexed under Sanitation. It is a rubbish-hauling licence. The collision is the word collector.

Three official instruments agree that no collection-agency regime exists:

1. The code index — no entry for collection agency, debt collector, creditor, consumer credit, or adjustment agency.
2. Ch. 81, License and Permit Fees, which is exhaustive on its own terms. § 81-1(1): "Upon issuance of a license or permit, the applicant shall pay to the city of Milwaukee a fee as listed in this chapter." Every Milwaukee licence therefore appears in ch. 81. The alphabetical schedule runs Cigarette → Cider → Class "A"–"D" → Code and Charter → Commercial Driver → Concrete Contractor with no collection-agency line. No fee, no licence.
3. The Common Council's legislative record (Legistar, current through 2026-09-01): collection agency, debt collector, debt buyer and medical debt return zero matters, ever. debt collect returns two, neither regulatory — File 160855 (2016) extends the City's own collection contracts, and File 210330 (2021) supports a federal bill and remains in committee.

Wisconsin regulates collection agencies at state level only (DFI).

⚠ Currency caveat. Instruments 1 and 2 are Internet Archive captures dated 2025-03-09, because the live host is Cloudflare-walled; the live index is dated 2026-07-14. Instrument 3 closes the gap by argument: ch. 81 changes only by ordinance, and the Council's live record shows none introduced in the interval. Re-verify against the live code when it can be reached — but the conclusion does not rest on it.

Open — checked but unresolved

Locality

Status

Los Angeles County + City of LA

Clear for licensing, but LA County Code Title 11 requires acute-care hospitals to report financial-assistance operations and debt-collection activities to Public Health (Board approved 2024-08, adopted 2024-09, data collection from 2025-03); the City of LA adopted it by motion 2026-02, reportedly enacted 2026-03-30. The duty runs to the hospital, not the collector, but it reaches a collector's activity through client contracts. Not yet a page; see the survey.

Traps / edge cases

1. "Cleared" is not "checked for everything." These localities were checked for a debt-collection-specific regime. Every one of them still has general business licensing, general UDAP ordinances, and a local consumer-affairs office that can act against a collector under general authority. Montgomery County MD is the clearest example: ch. 11 is a real consumer-protection law with a real enforcement office — it is simply not collection-specific.
2. A city hiring collectors is not a city regulating collectors. Jacksonville's 13 hits are ch. 112, which governs how the City contracts with agencies for its own receivables. Those terms bind an agency that takes the City's work — as a contract, not as an ordinance. If a GetPaid user holds a municipal contract, read the contract.
3. County ≠ its cities. Las Vegas is clear; Clark County, which contains it, is not (§ 6.12.315, a $300/yr collection-specific licence fee). Check both tiers. Similarly Yonkers sits inside Westchester County, which has its own conduct prohibition.
4. A 0-result read proves the phrase is absent, not that the concept is. See the method limits above.
5. Do not cite this page as authority for a locality's law. It records that a search found nothing on a date. For an affirmative statement about what a locality requires, cite the locality.

Related

• New York City — has a layer
• Yonkers — has a layer
• Buffalo — has a layer
• KB Index — the Local / municipal table lists every locality page
• State matrix — the state answer a cleared locality falls back to