Collections outreach
Seven calls in seven days. The eighth is the violation.
What goes wrong
Reg F did something unusual for a consumer-protection rule: it put a number on harassment. Seven calls to a consumer about a particular debt within seven consecutive days is presumptively compliant. The eighth is presumptively not. There is a second clock too -- seven days of silence after any telephone conversation about that debt.
An outreach agent optimising for contact rate will breach both without ever doing anything its instructions forbade. It is not misbehaving; it is counting differently, or counting per campaign rather than per debt, or not counting at all because the dialer and the agent maintain separate state.
The rest is equally countable: no contact before 8 a.m. or after 9 p.m. in the consumer's local time, no contact once a cease-communication request is in force, nothing disclosed to a third party, and nothing direct to a consumer known to be represented by counsel.
Who runs this today
- First-party collections teams running automated outreach sequencing across voice, SMS and email.
- Debt buyers and agencies where the FDCPA applies directly rather than by analogy.
- Card and auto lenders whose early-stage delinquency treatment is increasingly agent-driven.
Which controls apply
6 rules ship with the COLLECTIONS_OUTREACH template. Every
threshold is a number from a published rule, so a model-risk reviewer can
read the value and open the CFR rather than asking how it was fitted.
None of these rules decides credit.
| Control | Authority | Verdict |
|---|---|---|
| No More Than 7 Calls In 7 Days Per Account Reg F presumes a violation above seven calls to a consumer about a particular debt within seven consecutive days. The rule passes at six or fewer already placed, so the seventh call is permitted and the eighth is not. | Reg F 12 CFR 1006.14(b)(2)(i) | BLOCK |
| 7-Day Cooldown After A Telephone Conversation Reg F presumes a violation where the consumer is called about a debt within seven consecutive days of a telephone conversation about that debt. | Reg F 12 CFR 1006.14(b)(2)(ii) | BLOCK |
| Contact Only Between 8am And 9pm Consumer Local Time The FDCPA and Reg F treat contact before 8 a.m. or after 9 p.m. in the consumer's local time as inconvenient and prohibited absent consent. Expressed as a permitted hour range of 8 through 20 inclusive. | Reg F 12 CFR 1006.6(b)(1)(i) | BLOCK |
| Honour A Cease-Communication Request Once the consumer notifies in writing that they refuse to pay or want contact to stop, the FDCPA permits only narrow confirmatory contact. | 15 U.S.C. 1692c(c) | BLOCK |
| No Direct Contact Where Counsel Is Known Where the collector knows the consumer is represented by an attorney on the debt, contact must go to counsel. | 15 U.S.C. 1692c(a)(2) | BLOCK |
| No Debt Disclosure To Third Parties The FDCPA prohibits disclosing the debt to anyone other than the consumer, their spouse or their attorney. | 15 U.S.C. 1692c(b) | BLOCK |
What the evidence looks like
The sample below is a real BLOCK: the eighth call inside seven days. Note the reason states the count and the citation, so the record shows which limit was applied rather than merely that one was.
Sample evidence bundle
A real bundle from this template, exported through the same endpoint a customer would use. It carries the decision, the failed rules with their reasons, and the hash-chained audit events. You can verify it yourself without installing anything from us — the verifier is standalone and imports nothing from Sentinel.
A sensible pilot
The other three
The same gate governs all of them. Start where a wrong answer is recoverable, and move to credit decisioning when the evidence earns it.
Start in shadow mode
We are taking three design partners. Every deployment starts in OBSERVE, which evaluates everything and enforces nothing, so the first month costs you a report rather than a risk.
See the programme