Commercial and consumer obligations
Federal consumer collection law — the Fair Debt Collection Practices Act, and Regulation F which implements it — applies to debts incurred primarily for personal, family, or household purposes. It does not apply to commercial obligations, meaning money one business owes another arising from a business transaction.
Most of what we pursue is commercial. What determines the category is how the obligation originated, not who is being pursued for it. An obligation that began as a personal debt remains a consumer debt permanently, even if the person who owes it later operates through a business entity, and even where we are enforcing a judgment against that entity.
Our policy regardless of category
We honor validation requests, disputes, wrong-party notices, and communication preferences on any account we handle — whether or not federal consumer law requires it.
Determining whether a given obligation is commercial or consumer in origin is our responsibility, not yours. We do not require you to establish which category applies before we will respond to a request, and we do not decline a validation or dispute request on the ground that the obligation is commercial.
Validation information
You may request that we provide information substantiating the obligation, including the amount claimed, the name of the creditor to whom it is owed, and documentation of its origin. Where a judgment is involved, this includes the court, case number, and date of entry.
For consumer obligations, federal law requires that we provide validation information and that you have a period of at least 30 days from receipt of our initial communication in which to dispute the debt or request the name and address of the original creditor.
When you request validation, we pause collection activity on the account until we have obtained the requested information and provided it to you.
Disputing an obligation
You may dispute all or part of an obligation. A dispute may be based on the amount, on whether you owe it at all, on a payment or credit not reflected, on a defense such as non-delivery or breach, or on identity theft.
We record every dispute with a timestamp and a reference number, and we provide written acknowledgment. Where an obligation is disputed, we note the dispute on the account and communicate it to our client. We do not continue collection activity on a disputed consumer obligation until verification has been obtained and provided to you.
Communication restrictions
You may tell us how and when to contact you. Specifically, you may:
- Designate a preferred method of contact, or a method we should not use.
- Tell us not to contact you at a particular telephone number or email address.
- Tell us not to contact you at your place of employment.
- Specify times of day at which contact is inconvenient.
- Tell us you are represented by an attorney, after which we direct communication to your attorney.
- For consumer obligations, notify us in writing that you refuse to pay or that you wish us to cease further communication.
A request to cease communication does not extinguish the underlying obligation and does not prevent our client from pursuing other lawful remedies, including legal action through counsel.
Prohibited practices
We do not engage in the following, and no one contacting you legitimately on our behalf will:
- Threatening arrest, criminal prosecution, or law enforcement involvement.
- Claiming to be a government agency, a court, a law enforcement officer, or an attorney.
- Threatening any action we cannot lawfully take or that our client does not intend to take.
- Using obscene, profane, or abusive language.
- Misrepresenting the amount, character, or legal status of an obligation, including representing that a business owes an individual's personal debt absent a court finding.
- Requesting payment by gift card, cryptocurrency, wire transfer to an individual, or peer-to-peer payment application.
- Discussing an obligation with third parties other than as permitted by law.
If you are not the correct party
Debtor location is imperfect, and people with similar names or at prior addresses are sometimes contacted in error. If you are not the party we are looking for, tell us. We will note it, suppress the contact information associated with you, and stop contacting you at it.
If you believe the obligation resulted from identity theft, tell us that specifically. We will treat it as a dispute and request supporting documentation, which may include a police report or an identity theft report.
How to exercise these rights
Submit a request through the form on our Notice Recipients page, which records your submission with a timestamp and returns a reference number. You may also write to us at [MAILING ADDRESS] or call [PHONE] during [HOURS].
Requests that federal law requires to be in writing — notably a cease-communication request on a consumer obligation — should be submitted through the form or by mail so that a written record exists.
If you are dissatisfied with how we have handled a request, contact our compliance department at [COMPLIANCE EMAIL]. You may also contact your state attorney general or the Consumer Financial Protection Bureau at consumerfinance.gov/complaint. Contacting a regulator does not affect how we handle your account.