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1.4.4.1 Collection Prior to Charge-Off

In the Consumer Financial Protection Bureau’s survey of credit card issuers,246 all respondents conducted at least some collection activity in-house on overdue credit card accounts after a consumer misses a payment.247 These initial collection contacts may come in the form of letters, calls, emails, voicemails, or text messages reminding consumers of their outstanding balance. As described in § 1.4.5, infra, the majority of respondents also used first-party collectors for at least some of these early collection efforts.

All survey respondents have at least some contact limits on its in-house collectors.248 The CFPB summarized responses about contact limits as follows:249

  • • Phone calls: 4-15 per account per day;
  • • Postal mail: 0-2 per account per month;
  • • Voicemails: 0-2 per account per day;
  • • Email: 1-6 per account per month; and
  • • Text messages: 0-4 per account per month.

The majority of survey respondents indicated that they placed accounts with third-party collectors prior to charge-off with placement typically only made after sixty or ninety days of delinquency.250

No survey respondents sold debt prior to charge-off.251

Footnotes

  • 246 Consumer Fin. Protection Bur., The Consumer Credit Card Market 237 (Dec. 2015) (“surveyed issuers accounted for nearly three-quarters of the total amount of credit card balances outstanding”).

  • 247 Id. at 248.

  • 248 Id. at 248.

  • 249 Id. at 249.

  • 250 Id. at 250.

  • 251 Id. at 256.