1.4.5 Collection by First-Party Debt Collectors
The CFPB reports that the majority of credit card issuers that responded to its survey outsource some collection activities to first-party collectors.269 These first-party collectors may engage in collection tasks like “mailing a reminder to the consumer to pay a bill or placing a phone call a few days into delinquency.”270
Accounts are typically outsourced “before 60 to 90 days of delinquency.”271 First-party collectors are typically required to use the credit card issuers case management system and dialer and to comply with any contact limit policies that the credit card issuer maintains for internal collections.272
269 Consumer Fin. Protection Bur., The Consumer Credit Card Market 249 (Dec. 2015).
270 Id. at 243.
271 Id. at 248.
272 Id. at 248–249.