18.104.22.168 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.
- • 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
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.