When a borrower falls behind on a car loan or a credit card, the lender has to decide whom to call, text, email or write to each day, at what hour, and how many times this week. Federal, state and city rules cap how often and when, every team that phones a borrower uses up the same allowance, and the evidence says the right contact at the right hour beats more contacts. Those choices, made before anyone dials, are the contact strategy.
This guide is for collections strategy managers, collector team leads and supervisors, collections compliance analysts, heads of collections and recovery at banks, credit unions, card issuers and auto lenders, and the leaders deciding whether to automate the plan. No background needed.
Imagine you are a collections team lead at a regional bank in Columbus, Ohio. It is Tuesday, October 13, 2026, and your team of eight collectors has 486 past-due accounts and 712 contacts planned for the day. One of them is Dolores Ybarrola in Dayton: auto loan ending 0932, 34 days past due, $612.40 behind on a $14,820.55 balance. On September 30 she promised to pay by October 5. The promise broke on October 6.
Since then your dialer has called her six times: October 7, 8, 9 (a short voicemail), 10, 12, and at 9:06 this morning. Your bank applies the federal seven-calls-in-seven-days limit to its own collectors as policy, so she has one call left this week. The plan puts it at 2 p.m., the hour she answered on September 30. At 11:42 a.m. the day's first file from Branch 14 in Kettering arrives. A loan officer there called her at 11:31.
Your dialer's log · Oct 7–13
Calls
6
Last call
Oct 13, 9:06 a.m.
Calls left
1, planned 2 p.m.
Sees branch calls
No
Branch 14 call log · Oct 13
Calls
1
Time
11:31 a.m.
About
The past-due auto payment
Counted together
7 of 7: no more calls
2 p.m. call: the eighth in seven days6 p.m. email insteadnext call possible Wednesday, October 14.
She replied STOP to your texts on August 22, so texting is out. Four of her last five email opens were between 6 and 8 p.m., and she paid August's $612.40 from an email link at 7:14 p.m. on September 2. So the call comes off the plan, and an email with the amount, a payment link and a one-click opt-out goes at 6 p.m. Eastern, inside her local 8 a.m. to 9 p.m. Her next call can wait until Wednesday, when the October 7 call drops out of the seven-day window.
A contact strategy that counts every team's calls stops the eighth call before anyone dials it, and spends the contact on the channel and hour where she responds.
Deciding whom to contact in early-stage collections: segments, channels, hours, call limits and the evidence
How lenders decide whom to contact, how, when and how often once a borrower falls behind, the federal, state and city rules that cap those contacts, what studies say works, and how teams plan today. Written without naming any product. If you are new to collections, start here.
01 · In plain words
Collections contact strategy explained: whom to contact today, on which channel, at what hour, how often
When someone misses a loan or card payment, the lender usually hears nothing at first. Many people who miss one payment pay within a few weeks without being asked twice: they were traveling, a paycheck landed late, an automatic payment failed. Others are in real trouble and will fall further behind each month unless someone reaches them early with a workable plan. The first weeks after a missed payment are called early-stage collections, and they are where a lender has the most room to help and the most rules to follow.
Every morning a collections team has more past-due accounts than it can call. So someone has to decide which borrowers to contact today and which to leave alone, whether to call, text, email or send a letter, at what hour in the borrower's own time zone, and how many times this week. That set of decisions is the contact strategy. It is usually owned by a collections strategy manager and run each day by team leads through a dialer, the phone system that places calls from a list.
The rules are tight. A federal regulation, Regulation F, presumes that a debt collector harasses a borrower if it calls about one debt more than seven times in seven days, or calls again within a week of speaking with the borrower about it.1 Calls before 8 a.m. or after 9 p.m. in the borrower's local time are presumed inconvenient.2
Massachusetts allows two calls or texts a week to a personal number and applies that to lenders collecting their own loans.3 New York City, from September 1, 2026, allows three contacts a week per account by phone, text, email or any other medium except a mailed letter.4 Texts and robocalls also need consent under a separate federal law, and a borrower can withdraw that consent by replying STOP.5,6
Inside those limits the strategy chooses where to spend each contact. Studies of real lenders find that a personal conversation raises repayment, that text reminders help when they are personal, and that past a few contacts a week most people feel hounded.7,8,9 A good contact strategy reaches the people who need a conversation at the hour they answer, gives a light reminder to those who will pay anyway, and keeps an exact count of every contact from every team so nobody makes the call that breaks the rule.
The first weeks after a missed payment, in five steps
A payment is missedDolores Ybarrola's October auto payment of $612.40 is late. The account joins the bank's early-stage collections list.
The account is scored overnightDays past due, balance, payment history and past contacts give a chance of paying unaided, a chance of falling further behind, and the hours she answers.
Today's contacts are plannedWhom to contact, by which channel, at what local hour and how often, inside every federal, state, city and bank limit. This is where the eighth call is caught, or made.
Collectors make contactCalls are placed, emails and texts approved and sent, promises to pay recorded. Branches and outside agencies contact some borrowers too.
Results are measured and the strategy testedPromises per contact, payments, accounts that fall further behind, complaints and opt-outs, with changes tried on a random group first.
Step 3 is the subject of this guide. Sibling guides cover what the collector says on the call, checking calls afterwards, and hardship plans. The people, bank and figures in this example are fictional.
Examiners, branch calls, Honolulu time and contact fatigue: four surprises
Seven calls is a presumption, and examiners look past it
Regulation F says a collector who stays within seven calls a week per debt is presumed to comply. In a July 2024 report, CFPB examiners described collectors who stayed within that number but placed over 100 calls to people who had asked them to stop, and found the calls harassing.10
The count belongs to the debt, whoever dials
The federal limit counts calls per debt, whichever phone number is dialed.1 A collector's own branch staff and payment-reminder line call about the same loan, yet their calls often sit in systems the collections dialer cannot see.
The clock is the borrower's
The 8 a.m. to 9 p.m. window runs on local time where the borrower is.2 For a borrower in Honolulu in October, the first allowed call from an Eastern floor is at 2 p.m. Eastern. New York City instead writes Eastern Time into its rule.4
Past a few contacts a week, most people say it is too many
In the CFPB's national survey, 74% of people contacted one to three times a week about a debt said it was too often, and 91% of those contacted eight or more times.9 Complaints about frequent calls are the largest group of communication complaints.11
Contact-plan vocabulary: right-party contact, roll rate, conversation week, limited-content message
Right-party contact
A conversation with the borrower, or someone allowed to discuss the debt. A voicemail or a spouse taking a message does not qualify.
Roll rate
The share of accounts in one past-due group that move to the next group a month later, for example from 1–29 days late to 30–59.
Conversation week
The seven days, starting on the day of a phone conversation about a debt, in which Regulation F presumes a further call about that debt is harassment.
Limited-content message
A voicemail that says only who is calling and how to call back, with no mention of the debt. Regulation F defines what it may contain.12
The four decisions behind every collections contact plan, and the data each one needs
In shortA contact plan answers four questions for every past-due account, every day: whether to contact the borrower at all, by which channel, at what hour, and how many times this week. Each answer needs its own data, and each one is limited by a different rule.
Decision
What it weighs
Data it needs
Rules that limit it
Who
Chance of paying unaided, chance of falling further behind, balance at risk, hardship signals
Days past due, payment and promise history, risk score, product, prior contacts
Stops for bankruptcy, a cease letter or an attorney; fair lending rules on who is treated how13
Which channel
Where this borrower responds, cost, privacy, consent
Answer and open history by channel, consent and opt-outs, numbers and addresses on file
Regulation F email and text procedures and opt-outs; TCPA consent for texts and robocalls; refused media2,5,1
What hour
When this borrower answers or reads
Time zone from address and area code, stated inconvenient times, answer history by hour
8 a.m. to 9 p.m. local; known inconvenient times and places; work restrictions; city rules on Eastern Time2,4
How often
Urgency against annoyance and the remaining allowance
Every call, text, email and letter about the debt from every team and agency, conversations, promises
7 calls per debt in 7 days and the conversation week; Massachusetts 2; Washington 3; New York City 31,3,14,4
How collectors reach people, and how people would rather be reached
The CFPB's national survey of 2,132 consumers, fielded in 2015 and published in January 2017, remains the largest public study of how people experience collection contacts. Phone calls and letters dominated. Asked how they would most like to be contacted about a debt in collection, those who had been contacted put the letter first and the cell phone second. Text came last, though texting has grown a great deal since 2015.9
Phone and letter were how most people were contacted about a debt
Share of consumers contacted about a debt in collection, by method (more than one allowed)
Letters and cell phones are the methods people most prefer
Most preferred method, consumers contacted about a debt in collection
Letter42%
Cell phone21%
Email11%
Home phone9%
Voicemail3%
Text message1%
Source9 · Survey fielded 2015; shares do not sum to 100 because work phone, unspecified phone, social media and ambiguous answers are left out.
Show the numbers
Method
Most preferred
Letter
42%
Cell phone
21%
Email
11%
Home phone
9%
Voicemail
3%
Text message
1%
The same survey found in-person visits the least wanted method, and the cell phone split opinion: among people contacted about a debt, 21% named it their favorite way to be reached and 18% their least favorite.9 A contact strategy that records each borrower's stated preferences, and uses them, starts ahead of one that applies a single cadence to everyone.
A plan is a schedule of contacts. Most floors still express strategy as a sequence: letter on day 5, text on day 8, calls from day 10. A contact plan turns that sequence into a daily schedule of specific borrowers, channels and hours, recalculated as new contacts and promises arrive. The sequence is still useful as the default; the daily schedule is where the limits are enforced.
03 · Segments and roll rates
Segmenting early-stage accounts by risk, roll rate and the chance they pay on their own
In shortEarly-stage collections covers roughly the first 90 days past due, before an account is charged off or sent to an outside agency. Lenders sort these accounts by how likely they are to fall further behind and how likely they are to pay unaided, then spend their limited contacts where they change the outcome. Roll rates measure whether that works.
Bank regulators set the end of the road. Under the federal banking agencies' retail credit policy, a closed-end loan such as an auto loan is classified as a loss and charged off at 120 days past due, and an open-end account such as a credit card at 180 days. The same policy limits how often a lender may re-age an account to current: no more than once in twelve months and twice in five years for open-end accounts, and only after the borrower makes three consecutive minimum payments.15 Everything a contact strategy does happens inside that clock.
A past-due auto loan has 120 days before charge-off; a card has 180
Day 1Payment missed
Many lenders send a reminder; most early accounts are still reachable.
Days 1–29Early reminders
Light contact; a share of accounts pay unaided.
Days 30–59First bucket
Calls, texts and emails; promises to pay and payment plans.
Days 60–89Second bucket
Higher risk of rolling; hardship options and more contact.
Day 120Closed-end charge-off
Auto and installment loans classified loss under the federal policy.
Day 180Open-end charge-off
Credit cards classified loss under the federal policy.
Our reading of the sources15 · Bucket names vary by lender; the charge-off days are from the 2000 interagency policy.
Show the numbers
When
What
Day 1
Payment missed
Days 1–29
Early reminders
Days 30–59
First bucket
Days 60–89
Second bucket
Day 120
Closed-end charge-off
Day 180
Open-end charge-off
Roll rates, worked through
A roll rate is the share of accounts in one past-due bucket at month end that sit in the next bucket a month later. If 1,000 accounts are 1–29 days late at the end of September and 230 of them are 30–59 days late at the end of October, the roll rate from the first bucket to the second is 23%. Multiply the rates through the buckets and you get the share that will reach charge-off if nothing changes. The figures below are illustrative; your own roll rates come from month-end delinquency files you already keep.
Of 1,000 accounts a few days late, an illustrative 18 reach charge-off
Accounts at each bucket a month apart, using roll rates of 23%, 40%, 55% and 35%
1–29 days late1,000 accounts
30–59 days late230 accounts
60–89 days late92 accounts
90–119 days late51 accounts
Charged off18 accounts
Illustrative · replace with your own numbers · Replace the rates with your own by product; card and auto rates differ.
Show the numbers
Stage
Count
1–29 days late
1,000 accounts
30–59 days late
230 accounts
60–89 days late
92 accounts
90–119 days late
51 accounts
Charged off
18 accounts
The lever a contact strategy pulls is the first two arrows. Every account kept out of the 30–59 bucket is an account that never needs the expensive later work. The same allowance leaks at the other end: accounts that would have paid unaided still absorb calls if they are on the list, and each of those calls uses the borrower's weekly allowance and the collector's hour.
Four common segments, and what each one needs
Spend calls where the borrower is reachable and the risk of rolling is high
Risk of falling further behind →
Find them, then write
Call early, best hour
Remind, then wait
One reminder, no call
Number disconnectedBroken promiseAutopay failedPays late, rarely answers
Likely to answer or respond →
Illustrative · replace with your own numbers · Top left: hard to reach, high risk. Top right: reachable, high risk. Bottom left: hard to reach, low risk. Bottom right: reachable, low risk. Positions are examples; your scores decide where each account sits.
Show the numbers
Item
Likely to answer or respond (0–1)
Risk of falling further behind (0–1)
Number disconnected
0.13
0.62
Broken promise
0.80
0.74
Autopay failed
0.80
0.16
Pays late, rarely answers
0.13
0.20
Likely to pay unaided (often called self-cure). One reminder by the channel the borrower uses, and no call unless the payment does not arrive. No public figure gives the share of early-stage accounts that self-cure; it varies by product and lender, and your own history shows it.
Broken promise. A promise to pay that failed is a strong signal. The borrower answered once, so the hour and channel that worked are known.
Unreachable. Wrong or disconnected numbers. Location work and letters come first; repeated dialing of a dead number uses nothing but time, though calls that ring count toward the federal limit.1
Hardship signals. Job loss, illness, a natural disaster. These accounts go to a person and a hardship conversation, which a sibling guide covers.
04 · The 7-in-7 rule
The 7-in-7 rule worked day by day: seven calls per debt, the conversation week and the calls left out of the count
Status as of October 2026
In shortRegulation F, in force since November 30, 2021, presumes a debt collector complies with the ban on repeated calls if it calls about a particular debt no more than seven times in seven consecutive days and not at all for seven days after a phone conversation about that debt. More calls create a presumption of a violation. Both presumptions can be rebutted. Texts and emails sit outside this count; ringless voicemails sit inside it.
The rule is in 12 CFR 1006.14(b). A debt collector "is presumed to comply" if it places a telephone call to a particular person about a particular debt neither "more than seven times within seven consecutive days" nor "within a period of seven consecutive days after having had a telephone conversation with the person" about that debt, and "the date of the telephone conversation is the first day of the seven-consecutive-day period".1 Exceed either and the collector is presumed to violate the rule. The rule took effect on November 30, 2021.16,17
Who the rule binds
Regulation F applies to debt collectors as the Fair Debt Collection Practices Act defines them: mainly third-party collection agencies and debt buyers. A bank or credit union collecting its own loans is usually outside that definition. The CFPB's examination manual puts it plainly: the FDCPA and Regulation F apply "only if the entity is a 'debt collector'", while the ban on unfair, deceptive or abusive acts and practices "applies to all supervised entities".18
Many lenders apply the 7-in-7 limits to their own collectors as written policy, because their agencies are bound by them, because examiners judge harassment by frequency, and because state and city rules reach lenders directly.3,4 The CFPB withdrew its 2013 bulletin on unfair practices by first-party collectors on May 12, 2025, among 67 guidance documents; the law behind it was unchanged.19
Dolores Ybarrola's week, call by call
Take the example from the top of this page, where the bank applies the limit as policy. She spoke with a collector on September 30, which closed calls about that loan through October 6. Six dialer calls followed between October 7 and the morning of October 13, then a branch call at 11:31 a.m. on October 13.
The eighth call becomes possible the day the first call leaves the window
Dolores Ybarrola's auto loan, days from September 30, 2026
No calls allowedCalls counted
Conversation week: Sep 30 to Oct 6
Window Oct 7–13: 7 calls (6 dialer, 1 branch)
Planned 2 p.m. call, Oct 13: would be the eighth
Window Oct 8–14: 6 calls, one call allowed Oct 14
Sep 30Oct 7Oct 14
Fictional example from this guide
Show the numbers
Activity
From
To
Conversation week: Sep 30 to Oct 6
0
7
Window Oct 7–13: 7 calls (6 dialer, 1 branch)
7
14
Planned 2 p.m. call, Oct 13: would be the eighth
13
14
Window Oct 8–14: 6 calls, one call allowed Oct 14
8
15
On October 14 the October 7 call drops out of the window, leaving six calls in October 8–14, so one more call is allowed. Had she instead answered the branch call and talked about the payment, a new conversation week would start on October 13 and no call would be allowed until October 20. That second case is Kevin Mensforth's, later in this guide.
What counts toward the limit, and what does not
Counted: every call placed about the debt that connects to the dialed number, answered or not, including a call that is answered and drops. A ringless voicemail counts as a call.1
Excluded: calls that never connect (busy signal, number not in service); calls placed within seven days after the person gives prior consent directly to the collector, as when a borrower says "call me back Monday"; and calls to the borrower's attorney or a consumer reporting agency and other parties listed in the rule.1
Outside the count: text messages and emails. The commentary says placing a call "does not include sending an electronic message".1 They are still subject to the harassment ban and to the rules on time, opt-outs and media covered in the next section.
Per debt: "particular debt means each of a consumer's debts in collection", except student loans serviced under one account number, which count as one.1 A borrower with a past-due card and a past-due car loan has two counts.
When the presumption gives way
The commentary lists factors that can rebut a presumption of compliance: calls in rapid succession (two unanswered calls to the same number within five minutes), a highly concentrated pattern (seven calls in one day), the frequency of voicemails, and what the person said earlier, such as asking not to be contacted again.1 Factors that can rebut a presumption of a violation include a call required by law, a call about active litigation, and a call to deliver information the borrower asked for.1
The CFPB's 2024 exam findings show how this plays out: collectors who placed over 100 calls after being asked to stop kept within the numbers, and the examiners still found the calls harassing.10
What counts in each rulebook
A text counts in Massachusetts and New York City but not in the federal call limit
Does each kind of contact count toward the limit?
Not countedUnsettledCounted
Regulation F 7-in-7Massachusetts 2 per weekNew York City 3 per weekAnswered callCountedCountedCountedCall that rings, no answerCountedCountedCountedBusy or not in serviceNot countedUnsettledNot countedRingless or recorded voicemailCountedCountedCountedText messageNot countedCountedCountedEmailNot countedNot countedCountedLetterNot countedNot countedNot countedBorrower calls inNot countedNot countedNot counted
Our reading of the sources1,3,4,20 · Our reading of the texts. Massachusetts counts calls to personal numbers; its high court held in 2018 that unanswered automated calls can count. Check exceptions with counsel.
Show the numbers
Regulation F 7-in-7
Massachusetts 2 per week
New York City 3 per week
Answered call
Counted
Counted
Counted
Call that rings, no answer
Counted
Counted
Counted
Busy or not in service
Not counted
Unsettled
Not counted
Ringless or recorded voicemail
Counted
Counted
Counted
Text message
Not counted
Counted
Counted
Email
Not counted
Not counted
Counted
Letter
Not counted
Not counted
Not counted
Borrower calls in
Not counted
Not counted
Not counted
05 · Texts, emails and consent
Texts and emails under Regulation F, and the FCC's consent-revocation rules of April 2025 and November 2026
Status as of October 2026
In shortTwo sets of rules govern electronic contact. Regulation F sets the procedures for collection emails and texts, requires a simple opt-out in every one, and times each message from when it is sent. The Telephone Consumer Protection Act (TCPA) requires consent for autodialed or prerecorded calls and texts to cell phones; the FCC's 2024 rules on withdrawing that consent took effect on April 11, 2025. An October 2026 order replaces the delayed "revoke all" part: from November 25, 2026, a caller may name one exclusive way to opt out, and may treat a STOP to an informational message as covering only that kind of message.
Regulation F: the email and text procedures
Safe-harbor procedures. A collector may email an address the consumer used to contact it, or one the consumer consented to directly, or one the creditor used after giving the consumer a notice with at least 35 days to opt out.2
Texts and reassigned numbers. To use the safe harbor for a text, the collector confirms, using a complete and accurate database such as the FCC's reassigned numbers database, that the number has not passed to someone else.2
An opt-out in every message. Each email or text must carry "a clear and conspicuous statement describing a reasonable and simple method" to opt out, with no fee and no information beyond the opt-out itself.2
The time is when it is sent. "An electronic communication occurs when the debt collector sends it, not, for example, when the consumer receives or views it." An overnight email scheduled for 6 a.m. is a 6 a.m. communication.2
Refused media. If a person asks a collector not to use a medium, or a specific number or address, it must stop. "Stop calling" ends phone calls.1
Work email. A collector may not email an address it knows the employer provides, with narrow exceptions.21
The TCPA: consent, and how it is withdrawn
The TCPA requires prior express consent for calls and texts to a cell phone made with an autodialer or a prerecorded voice. In February 2024 the FCC adopted rules on revoking that consent, in force since April 11, 2025.5 A borrower may revoke "by using any reasonable method"; replying "stop", "quit", "end", "revoke", "opt out", "cancel" or "unsubscribe" to a text is a reasonable method in itself; until November 25, 2026 the caller may not insist on one exclusive method; revocations must be honored "within a reasonable time not to exceed ten business days"; and one confirmation text is allowed, presumed fine if sent within five minutes.5
One part never took effect. The 2024 rule said a revocation in response to one kind of message covers all later robocalls and robotexts from the same caller, including unrelated ones. Banks, credit unions, mortgage lenders and collectors asked for time, because a STOP to a fraud alert would have to halt collection texts too, and the FCC's consumer bureau waived that part to April 11, 2026, then, on January 6, 2026, to January 31, 2027.22
On September 30, 2026 the FCC adopted an order (FCC 26-67, released October 1) that replaces it and takes effect November 25, 2026, superseding the waived date.6
Scoped revocation. A STOP in answer to an informational call or text, such as a payment reminder, may be treated as covering only that category of message. A STOP to telemarketing still ends all telemarketing.6
An exclusive method. A caller may designate one of three ways to opt out as the only one it accepts: a key-press or voice opt-out on the call, a reply text with one of the standard words, or a website or phone number it names, disclosed clearly on every call or text. A caller that names none must accept any reasonable means.6
Unchanged. Ten business days to honor a revocation, and the five-minute confirmation text. The FCC is still asking whether to shorten the ten days and whether to require a one-step "revoke all" option.6
The FCC replaced its 'revoke all' rule before it ever took effect
Feb 16, 2024FCC releases revocation rules
Any reasonable method; ten business days; one confirmation text.
Oct 11, 2024Effective date set
The FCC announces April 11, 2025.
Apr 7, 2025First waiver
The revoke-all part is delayed to April 11, 2026.
Apr 11, 2025Rules in force
Revocation by any reasonable means; ten business days.
Jun 20, 2025McLaughlin v. McKesson
The Supreme Court holds district courts are not bound by FCC readings of the TCPA.
Jan 6, 2026Second waiver
Revoke-all delayed to January 31, 2027.
Oct 1, 2026FCC 26-67 released
Revoke-all replaced: STOPs may be scoped to one kind of informational message; callers may name an exclusive opt-out method.
Nov 25, 2026New rules take effect
Thirty days after Federal Register publication on October 26, 2026.
Courts read the TCPA for themselves now. In McLaughlin Chiropractic Associates v. McKesson, decided June 20, 2025, the Supreme Court held that district courts in TCPA enforcement suits are not bound by the FCC's interpretations of the law; they decide its meaning themselves, giving the FCC's view appropriate respect.23 Long-standing FCC readings that collections teams relied on, including how consent for collection calls is given, can now be argued afresh case by case. Keep a record of how and when each borrower's consent was given, and take your counsel's view on which readings you rely on.
06 · State and city caps
Massachusetts, Washington and New York City contact caps that are stricter than 7-in-7
Status as of October 2026
In shortRegulation F lets states and cities go further, and several do. Massachusetts allows two calls, texts or recorded messages a week per debt to a personal number and binds lenders collecting their own loans. Washington presumes harassment above three communications a week from a collection agency. New York City, since September 1, 2026, allows three contacts a week per account by any medium except mailed letters, and none for the rest of that week once the borrower responds. About half of state collection laws do not reach original creditors, so the map differs for a bank and for its agency.
Massachusetts allows the fewest contacts a week per debt
Contacts per debt in seven days before a limit or presumption applies
Regulation F (phone calls)third-party collectors7
Washington (communications)licensed agencies3
New York City (any medium but mail, per account)collectors, and creditors once collection procedures start3
Massachusetts (calls, texts, recorded messages)creditors and collectors2
2 telephone communications (in person, text or recorded audio) per 7 days per debt to a residence, cell or personal number; 2 per 30 days to other numbers3
8 a.m.–9 p.m. Eastern, unless the debtor's normal waking hours are known3
Creditors, including lenders collecting their own debts3
Washington, RCW 19.16.250
Harassment presumed above 3 communications a week, above 1 a week at work; calls or texts to a cell phone at most twice a day14
Not 9 p.m.–7:30 a.m. at home; time zone from a landline's area code, else the last known residence14
More than 3 communications or attempts in 7 days per account by any medium, or any after the consumer responds, is excessive; mail, consumer-initiated and unconnected attempts excluded4
Collectors, and original creditors once they stop statements, threaten suit or accelerate4
Massachusetts: the two-call rule, applied to lenders
Massachusetts' attorney general rule counts each "communication with any debtor via telephone, either in person or via text messaging or recorded audio message" and allows two in each seven-day period per debt to the debtor's own numbers.3 It defines a creditor broadly enough to cover a bank collecting its own loans.3
In Armata v. Target (2018) the state's highest court held that automated calls can count even when unanswered and no message is left, unless the creditor cannot reach the debtor or leave a message.20 In 2020 a federal court in Massachusetts let such a claim go forward: a utility's collection vendors were alleged to have placed more than two calls within seven days, and the court refused to dismiss the consumer-protection claim.24
New York City: three a week by any medium but mail, and the Eastern clock
New York City's Department of Consumer and Worker Protection adopted its new debt collection rule in February 2026, effective September 1, 2026. It counts communications and attempts by any medium, including limited-content voicemails, and treats as excessive more than three in seven consecutive calendar days per account, or any after the consumer has responded within the period. The seven days start with the first contact or attempt. Mailed letters, contacts the consumer starts, and attempts that never connect or bounce are left out of the count.4
The department noted that its earlier rule had treated more than two collection communications a week as excessive since 1979, so for collectors the change raises the weekly number from two to three.4 A lender is covered once it begins "debt collection procedures": it has stopped sending periodic statements, has threatened legal action, or has accelerated the balance. A card account that still receives monthly statements is usually outside the trigger, though many lenders apply the city cap to their whole New York City book to keep one rule.4
Where state laws stop
A Philadelphia Fed working paper that catalogued state collection laws found that "approximately half (26) do not apply to the original creditors".25 For a bank, the practical map is short: the states and cities whose rules name creditors, the bank's own policy, and the federal UDAAP standard. For its outside agency, the map is the full set. A contact plan that enforces the stricter of every rule that applies to the account and the caller gives one answer for both.
07 · Local time
What time debt collectors can call: the borrower's clock, conflicting area codes and inconvenient times
In shortFederally, contacts before 8 a.m. or after 9 p.m. at the consumer's location are presumed inconvenient, emails and texts included, and any time or place the borrower has said is inconvenient is off limits. When an area code and an address point to different time zones, the safe window is the hours that are convenient in both. New York City and Massachusetts set the window on Eastern Time; Washington opens at 7:30 a.m.
Regulation F bars contact "at any unusual time, or at a time that the debt collector knows or should know is inconvenient", and in the absence of other knowledge treats "a time before 8:00 a.m. and after 9:00 p.m. local time at the consumer's location" as inconvenient.2 The official commentary handles conflicting data with an example: a mobile number with an Eastern area code and a home address in the Pacific time zone. The convenient window is the overlap, "after 11:00 a.m. Eastern time (8:00 a.m. Pacific time) and before 9:00 p.m. Eastern time (6:00 p.m. Pacific time)".2
An Eastern floor can reach Honolulu only from 2 p.m. Eastern in October
The 8 a.m.–9 p.m. local window, shown in Eastern time, Tuesday, October 13, 2026
Eastern (Columbus, Dayton)
Central (Peoria)
Mountain (Denver)
Arizona, no daylight time (Phoenix)
Pacific (Spokane, Sacramento)
Alaska (Anchorage)
Hawaii (Honolulu)
8 amnoon4 pm8 pmmidnight
Our reading of the sources2 · Daylight saving time applies in October everywhere listed except Arizona and Hawaii. After daylight time ends on November 1, 2026, the Arizona and Hawaii windows start one hour earlier on the Eastern clock.
Show the numbers
Activity
From
To
Eastern (Columbus, Dayton)
8
21
Central (Peoria)
9
22
Mountain (Denver)
10
23
Arizona, no daylight time (Phoenix)
11
24
Pacific (Spokane, Sacramento)
11
24
Alaska (Anchorage)
12
25
Hawaii (Honolulu)
14
27
Times and places the borrower has ruled out
The 8-to-9 window is only the default. If a borrower says weekdays at work are impossible, or that Sunday mornings are, those hours close as well, and contact at a place of employment is barred where the collector knows or has reason to know the employer prohibits it; "cannot take personal calls at work" is enough.2 CFPB examiners in 2024 found collectors sending payment reminder emails before 8 a.m. local time, and collection staff continuing conversations after borrowers said they were at work, driving, or at church without a wallet.10
Three local rules on the clock
New York City writes the zone into its rule: "after 8 a.m. and before 9 p.m. Eastern Time", unless the collector knows otherwise.4 A New York City account whose borrower has moved to Phoenix has a window that is the overlap of both rules.
Massachusetts sets 8 a.m. to 9 p.m. Eastern when the debtor's normal waking hours are unknown.3
Washington presumes harassment for communications at home between 9 p.m. and 7:30 a.m., and presumes a landline call is received in its area code's time zone unless the agency reasonably believes otherwise.14
Federal law sets no weekend or holiday rule for collection contacts; a Saturday is an ordinary day under Regulation F unless the borrower has said it is inconvenient.2
08 · The evidence
What the studies show about call frequency, personal calls and text reminders
In shortRandomized studies of real lenders find that a personal conversation raises repayment, that text reminders raise on-time payment about as much as a large interest discount, and that reminders work best when they name a person. Surveys find most people feel contacted too often past a few contacts a week. Industry data shared with the CFPB suggest most borrowers who are ever reached are reached within the first seven calls.
Study
Setting
What it found
Laudenbach and Siegel, SAFE Working Paper 428, 2024
Delinquent borrowers of a bank, each call handled by a randomly assigned bank employee
Borrowers who spoke with a bank employee were significantly more likely to resolve the delinquency than those who did not, and less likely to fall behind again; how likeable the employee's voice sounded mattered.7
Cadena and Schoar, NBER Working Paper 17020, 2011
Microlender in Uganda; text reminders against cash rewards and rate cuts
A monthly text reminder raised the chance of paying on time by about as much as a 25% interest cut: 7–9% higher across treatments, and two fewer days late a month.26
Karlan, Morten and Zinman, Yale discussion paper, 2012
Two Philippine microlenders; randomized reminder texts
Messages "only robustly improve repayment when they include the loan officer's name", and only for borrowers that officer had served before. Framing and timing did not matter.8
Haynes, Green, Gallagher, John and Torgerson, 2013
5,450 people with unpaid court fines in England
A text message raised the average amount paid from £4.46 to £10.94; the message using the person's name worked best.27
CFPB calling data, Regulation F rule, 2020
Microdata from one large agency, summaries from others, two auto-lender trials
In one agency's data, about 40% of consumers got more than seven call attempts a week in the first four weeks; half or more of those ever reached were reached within seven calls; cutting calls raised roll rates in two lender trials, though differences were often not statistically significant.16
CFPB consumer survey, 2017
2,132 consumers nationally
63% of those contacted about a debt said too often; 42% asked a creditor or collector to stop, and one in four of them said the contact stopped.9
Above three contacts a week, about nine in ten say it is too often
Share of consumers contacted about a debt who said they were contacted too often, by how often they were contacted
Half or more of borrowers ever reached are reached within the first seven calls
50+ in 100
of consumers eventually reached were reached within the first seven calls overall, in data large collection agencies shared with the CFPB; others needed 15 to 21 calls to reach half
of consumers eventually reached were reached within the first seven calls overall, in data large collection agencies shared with the CFPB; others needed 15 to 21 calls to reach half
50 of 100
The same analysis found that in one agency's data, "consumers who take longer to reach are not less likely to pay", and that reaching 95% of those ever reached took 50 to 60 calls.16 So a cap on calls mostly delays contact for the hardest-to-reach few, and every call spent on someone who would have paid unaided is a call unavailable for them. Two automotive lenders' randomized trials, described in the same rule, found that reducing early-stage calls raised roll rates, though the CFPB noted that no confidence intervals were given and many differences were not significant.16
What the evidence leaves open
None of these studies measures the best hour to call, the best channel mix for a US auto or card book, or the size of the promise-to-pay gain from planning by hour. Those depend on your borrowers and are what a controlled test on your own accounts measures. Research on the wider effects of collection limits cuts both ways: a 2023 Journal of Finance study found that states which restricted collection practices saw less mainstream credit and more payday borrowing among affected consumers.28
09 · Champion/challenger
Champion/challenger testing in collections: control groups, sample sizes and the measures that matter
In shortA champion/challenger test runs today's strategy (the champion) and a proposed change (the challenger) side by side on randomly split accounts, then keeps whichever does better on measures set in advance. Small lifts need large groups: on a 12% promise rate, a one-point lift needs about 17,000 accounts on each side. Count complaints and opt-outs alongside promises.
A fair test is designed before it starts and decided on numbers set in advance
1Write the change
One change, for one segment: for example, an evening email before the first call for auto loans 31–45 days late.
Strategy managerDay 0
2Pick the measures
Promises per 100 contacts, contacts per promise, kept promises, roll rate, complaints, opt-outs.
Strategy manager and complianceDay 0
3Split at random
Accounts assigned by a random number, never by collector or region.
AnalyticsDay 1
4Run both sides
Same limits, same collectors, same weeks; only the change differs.
Collectors4 to 8 weeks
5Read the result
Compare against the size set in advance, with its uncertainty.
Analytics1 week
6Decide and record
Adopt, drop or extend, with the evidence filed.
Strategy manager1 day
Illustrative · replace with your own numbers
Show the numbers
Step
What happens
Who
Time
Write the change
One change, for one segment: for example, an evening email before the first call for auto loans 31–45 days late.
Strategy manager
Day 0
Pick the measures
Promises per 100 contacts, contacts per promise, kept promises, roll rate, complaints, opt-outs.
Strategy manager and compliance
Day 0
Split at random
Accounts assigned by a random number, never by collector or region.
Analytics
Day 1
Run both sides
Same limits, same collectors, same weeks; only the change differs.
Collectors
4 to 8 weeks
Read the result
Compare against the size set in advance, with its uncertainty.
Analytics
1 week
Decide and record
Adopt, drop or extend, with the evidence filed.
Strategy manager
1 day
How many accounts a test needs
The number of accounts depends on the baseline rate and the lift you want to detect. The figures below use a 12% baseline (12 in 100 accounts make a promise to pay in the test period), a two-sided 5% significance level and 80% power, the usual defaults. They are arithmetic, and the inputs are illustrative.
Detecting a one-point lift takes about 22 times as many accounts as a five-point lift
Accounts needed on each side of a test, 12% baseline promise rate, 5% significance, 80% power
+1 point (12% to 13%)17,168 accounts
+2 points (12% to 14%)4,437 accounts
+3 points (12% to 15%)2,036 accounts
+5 points (12% to 17%)777 accounts
Illustrative · replace with your own numbers
Show the numbers
Lift to detect
Accounts per side
+1 point (12% to 13%)
17,168 accounts
+2 points (12% to 14%)
4,437 accounts
+3 points (12% to 15%)
2,036 accounts
+5 points (12% to 17%)
777 accounts
If promises are counted per contact rather than per account, the contacts within one account are not independent, so treat the account as the unit. A team with 486 accounts in early-stage collections tests a large change on one team, or a small change across several teams over more weeks.
Reading a contact test: promises, cures, roll rates, contact rate and complaints
Measure
How
Why it matters
Promises per 100 contacts
Promises to pay ÷ contacts made × 100
What each unit of the limited allowance buys
Kept promises and cure rate
Promises paid on time; accounts back to current
A promise that breaks is a delay
Roll rate
Share moving to the next bucket at month end
Shows whether fewer calls cost money later
Right-party contact rate
Conversations with the borrower ÷ accounts attempted (state the denominator)
Shows whether the hour and channel are right
Complaints and opt-outs
Per 1,000 accounts, by channel
The cost a promise count hides
Right-party contact rate has three common denominators: dials, connected calls and accounts attempted. They give three different numbers from the same day, so a benchmark is only comparable when the denominator is stated. Test results belong in the record a strategy change is approved from; under the 2026 model risk guidance, a scoring model's performance and its changes are also subject to the bank's own model governance.29
10 · Over-contact
Over-contact in complaints, exam findings, settlements and court cases since 2014
In shortThe CFPB received about 387,400 debt collection complaints in 2025, up from about 207,800 in 2024, and in 2024 frequent or repeated calls were the largest group of communication complaints. Examiners have found harassment inside the 7-in-7 numbers, the Massachusetts attorney general has settled with a lender over excessive collection calls, and collection calls to cell phones without consent have produced some of the largest TCPA settlements.
387,400
debt collection complaints the CFPB received in 2025, against about 207,800 in 2024 (7% of all complaints that year).30,11
Complaints received, CFPB annual reports
51%
of complaints about communication tactics were about frequent or repeated calls; 34% about contact after a request to stop.11
Complaints received in 2024
100+
calls placed after consumers asked collectors to stop, found harassing by examiners although within the 7-in-7 numbers.10
CFPB Supervisory Highlights, July 2024
Half of communication complaints are about how often collectors call
Complaints about collectors' communication tactics, 2024
Among electronic communication complaints in 2024, 58% were about frequent or repeated messages and 32% about messages that continued after the consumer asked them to stop.11 New York City cited its complaint counts when it adopted its three-a-week rule.4
Over-contact cases, from Capital One's $75 million to the 2024 exam findings
When
Who
What happened
August 2014
Capital One and three collection agencies
Agreed to settle a consolidated TCPA class action for more than $75 million (preliminary court approval that summer), at the time the largest TCPA settlement, over autodialed and prerecorded collection calls to cell phones without consent, including calls after requests to stop and calls to numbers found by skip tracing.31
June 2018
Armata v. Target, Massachusetts Supreme Judicial Court
Held that a creditor's automated calls can count toward the two-call limit even when unanswered and no message is left.20
August 2020
Nightingale v. National Grid, D. Mass.
A utility's collection vendors were alleged to have placed more than two calls in a week; the court held the complaint stated a claim under Chapter 93A.24
February 2023
Massachusetts attorney general and Toyota Motor Credit Corporation
A $7.6 million settlement ($5.5 million in debt relief, $2.1 million in penalties) over alleged collection practices including excessive collection calls under 940 CMR 7.04(1)(f).32
July 2024
CFPB supervision, unnamed collectors
Harassment within the 7-in-7 numbers after stop requests; texts to numbers consumers had refused; emails before 8 a.m. local time; conversations continued after "bad time".10
2024
Federal enforcement
The FTC was the only federal agency to announce public FDCPA enforcement actions in 2024; the CFPB brought or resolved none.11
Federal FDCPA enforcement was thin in 2024, and the CFPB withdrew its first-party collection guidance in May 2025.11,19 The private side remains active: TCPA and state-law claims are brought by borrowers and their lawyers, and city and state rules keep tightening. A strategy built to stay inside every applicable limit, with a record of why each contact was allowed, is cheaper to defend than one built to the federal minimum.
11 · Scores and fair lending
Contact scores under fair lending rules, the 2026 model risk guidance and Colorado's automated-decision law
Status as of October 2026
In shortScores that decide who is called, who gets a reminder only, and who waits are part of a credit transaction under the Equal Credit Opportunity Act, because Regulation B includes collection procedures. Statistical scores are models under the April 2026 model risk guidance. Colorado's automated-decision law covers lending services from January 2027. Keep protected characteristics and their close stand-ins out of the inputs, and test the outcomes.
Regulation B defines a credit transaction as "every aspect of an applicant's dealings with a creditor", expressly including "collection procedures".13 Treating borrowers differently in collection because of race, sex, age or another prohibited basis is disparate treatment. A CFPB rule effective July 21, 2026 states that ECOA does not authorize disparate-impact liability; it is being challenged in court, and the ban on disparate treatment is unchanged.33 A contact score built on inputs that stand in for a protected characteristic, such as language or neighborhood, still invites questions from examiners, state attorneys general and borrowers.
The joint model risk guidance issued April 17, 2026 (Federal Reserve SR 26-2, OCC Bulletin 2026-13, FDIC FIL-15-2026) replaced SR 11-7. It covers statistical and machine-learning models such as a score of how likely a borrower is to answer, promise or pay unaided; fixed rules such as a call limit are outside its model definition.29 Colorado's SB26-189, signed May 14, 2026, requires notice, explanation and human review for automated decisions in "financial or lending services" from January 1, 2027; whether a collection contact plan is such a decision is a question for counsel.34
Scores that rank borrowers carry the most rules; contact counting carries the collection rules
Which rule applies to each part of a contact-planning tool
Usually notPossiblyApplies
Regulation F and UDAAPTCPAECOA (Reg B)Model risk (SR 26-2)Colorado SB26-189Counting every contact per debtAppliesPossiblyUsually notUsually notUsually notChecking limits, hours and opt-outsAppliesAppliesUsually notUsually notUsually notScoring reach and promise by hourPossiblyUsually notAppliesAppliesPossiblySkipping accounts likely to pay unaidedPossiblyUsually notAppliesAppliesPossiblyChoosing text or emailAppliesAppliesPossiblyUsually notPossiblyChampion/challenger testsPossiblyUsually notAppliesPossiblyUsually not
Our reading of the sources1,5,13,29,34 · Our reading; Colorado's coverage of collection decisions is untested.
Show the numbers
Regulation F and UDAAP
TCPA
ECOA (Reg B)
Model risk (SR 26-2)
Colorado SB26-189
Counting every contact per debt
Applies
Possibly
Usually not
Usually not
Usually not
Checking limits, hours and opt-outs
Applies
Applies
Usually not
Usually not
Usually not
Scoring reach and promise by hour
Possibly
Usually not
Applies
Applies
Possibly
Skipping accounts likely to pay unaided
Possibly
Usually not
Applies
Applies
Possibly
Choosing text or email
Applies
Applies
Possibly
Usually not
Possibly
Champion/challenger tests
Possibly
Usually not
Applies
Possibly
Usually not
Contact decisions that stay with collectors, compliance and the strategy manager
Placing calls and approving the content of collection emails and texts.
Hardship conversations, disputes, and anything said about bankruptcy, death or military service.
Changing a rule or a limit, which belongs to compliance.
Adopting a strategy change, which belongs to the strategy manager, on the evidence of a controlled test.
12 · The market
Delinquency in 2026: card and auto flows into early collections, and the falling answer rate
In shortMore balances are entering early delinquency than before the pandemic. In the second quarter of 2026, an annualized 8.7% of credit card balances and 7.9% of auto balances moved into delinquency, against 7.0% and 6.9% at the end of 2019. Collection teams also report that fewer calls reach the borrower, with call blocking and spam labels the most cited reason.
More card and auto balances are entering delinquency than before the pandemic
Share of balances transitioning into 30+ days delinquent, annualized, fourth quarter of each year (Q2 2026: cards 8.69%, auto 7.87%)
The New York Fed's household debt report puts credit card balances at $1.263 trillion and auto loans at $1.713 trillion at the end of June 2026, with 4.7% of all household debt in some stage of delinquency. The flow of card balances into serious delinquency (90 days or more) was 6.97%, and of auto balances 3.00%. 4.9% of consumers had a third-party collection account on their credit report.35
About one call in four reaches the borrower in UK collection centers
26 in 100
mean right-party contact rate in a 2024 survey of UK debt collection contact centers; we found no comparable published US figure
About 160,200 people worked as bill and account collectors in the US in 2025, at a median wage of $22.61 an hour, and BLS projects the occupation to shrink slightly over the next decade.38 With fewer collectors, more balances falling behind and fewer calls answered, each collector's call hour carries more weight, which is the economic case for planning each contact by account, channel and hour.
What nobody publishes. We found no public US figure for the share of early-stage accounts that pay unaided, promises to pay per 100 contacts, cost per contact by channel, or the share of collection calls placed by branches, servicing lines or agencies outside the collections dialer. Each is in your own data.
13 · How teams plan today
How collections floors build the day's contact plan today: roles, hand-offs and where the hours go
In shortA strategy manager sets segments and cadences, the dialer runs campaign lists by time zone, team leads rebuild the day's order from spreadsheets, collectors work the queue, and compliance answers for each call afterwards. The weak point is the count: calls from branches, servicing lines and agencies arrive late or never, so the limit is enforced on part of the picture.
Strategy manager, team lead, collector, compliance and the other callers
SM
Collections strategy manager
Owns segments, channel mix, cadences and tests; reports promises, cure rates and roll rates.
Cares about: more promises from the same contacts.
TL
Collector team lead
Turns the strategy into today's order for eight to twelve collectors and re-plans when the day changes.
Cares about: a list that is still right at 10 a.m.
CO
Collector
Places calls, sends approved messages, records promises and hardship flags.
Cares about: never being the one who made the eighth call.
CA
Collections compliance analyst
Owns the contact rules, monitors calls and builds the evidence for examiners.
Cares about: why a given call was allowed, in one click.
BR
Branches, servicing lines and outside agencies
Also contact past-due borrowers, often from their own systems.
Cares about: their own customer conversation, rarely the collections count.
From the nightly file to the dialer queue: six hand-offs
Today's plan passes through four systems before the first call
1Nightly file
Accounts, days past due, balances and promises from the loan system.
OperationsOvernight
2Segment and score
Risk, self-cure and reach scores; treatment by segment.
Strategy manager and analyticsOvernight
3Campaign lists
Lists loaded to the dialer by time zone; texts and emails queued.
Dialer administratorBefore 8 a.m.
4Order the day
Team lead adjusts for counts, promises and staff from a spreadsheet.
Team leadFirst hour
5Work the queue
Calls placed, promises recorded; branches and agencies call too.
CollectorsAll day
6Answer for it
Compliance reconstructs a call's context from several systems when asked.
Compliance analystAfter the fact
Illustrative · replace with your own numbers · Times are illustrative for an early-stage team.
Show the numbers
Step
What happens
Who
Time
Nightly file
Accounts, days past due, balances and promises from the loan system.
Operations
Overnight
Segment and score
Risk, self-cure and reach scores; treatment by segment.
Strategy manager and analytics
Overnight
Campaign lists
Lists loaded to the dialer by time zone; texts and emails queued.
Dialer administrator
Before 8 a.m.
Order the day
Team lead adjusts for counts, promises and staff from a spreadsheet.
Team lead
First hour
Work the queue
Calls placed, promises recorded; branches and agencies call too.
Collectors
All day
Answer for it
Compliance reconstructs a call's context from several systems when asked.
Compliance analyst
After the fact
A team lead's planning day, task by task
Rebuilding the order and chasing other teams' calls take most of a team lead's planning time
Hours a day, one early-stage collections team, by hand
Rebuilding the call orderChasing branch and agency callsChecking local hours and state limitsRe-ordering after new contactsAnswering compliance about one call
By hand, about 4.5 hours1.5 h1 h0.75 h0.75 h0.5 h
Illustrative · replace with your own numbers · An estimate; time your own team leads for a week.
Show the numbers
Rebuilding the call order
Chasing branch and agency calls
Checking local hours and state limits
Re-ordering after new contacts
Answering compliance about one call
By hand, about 4.5 hours
1.5 h
1 h
0.75 h
0.75 h
0.5 h
Dialer rules, an outside agency or decision software: three ways to plan contacts
In house
Dialer rules and spreadsheets
Campaign rules in the dialer, counts and exceptions in a spreadsheet. Cheap and familiar; the count covers only what the dialer placed.
Outsourced
Placement with an agency
Early-stage work placed with a collection agency bound by Regulation F. The lender keeps responsibility for its vendor and for its own calls.
Software
Decision and contact platforms
Decision engines and contact platforms that segment, score and enforce limits. They differ most on whether they count contacts from every source and plan by hour.
Part B · See it working
Botminds Collections Contact Strategy on one Ohio team's Tuesday: 486 accounts, 712 contacts, every limit counted
Part A described the work without naming a product. This part shows how Botminds plans contacts for a fictional bank's early-stage collections team in Columbus, Ohio, on Tuesday, October 13, 2026. Every bank, borrower, collector and figure on these screens is sample data.
14 · One morning, one branch call
One branch call at 11:31 a.m.: how the plan for Dolores Ybarrola changes before her 2 p.m. call
In shortThis is the example from the top of the page, inside the product. Agents build Team 2's plan at 8:02 a.m. from six contact sources, gray out every hour the rules forbid, and place each account in the hour and channel where the borrower is most likely to respond. At 11:42 a.m. a branch call log arrives; the agents count the branch's call to Dolores Ybarrola as her seventh, remove her 2 p.m. call and plan a 6 p.m. email, which waits for her collector's approval.
1
The day's plan, built at 8:02 a.m.
Before the floor logs in, the agents read 1,904 contacts from the last seven days across six sources: the collections dialer, branch call logs, texts, email, the letters vendor and the outside agency, Pinecrest Recovery Group. They check 486 accounts at every hour and channel and plan 712 contacts for eight collectors: 431 calls, 148 texts, 117 emails and 16 letters, with none outside a limit.
Each row is an account and each column an hour on the floor's Eastern clock. Shading shows how likely the borrower is to respond at that hour. Rows for Phoenix, Spokane and Honolulu start later because the 8 a.m. to 9 p.m. window is local. Gray cells carry their reason: 7 in 7, a Massachusetts or New York City cap, "at work", a stop.
Today's contact plan. Fourteen of Team 2's accounts, each contact in the hour it is most likely to land, and every forbidden hour grayed with its reason.
2
Every gray cell has a reason
Jordan Pike, the team lead, clicks Marcus Tellford's 3 p.m. cell. Marcus lives in Worcester, Massachusetts, where a creditor may make two telephone contacts a week per debt to a personal number, and both are used. No calls until Friday, October 16; text and email are still allowed.
The rule is the state's, the count includes every team's calls, and the cell shows how likely each remaining channel is to land at that hour.
A Massachusetts limit. Two calls in seven days used under 940 CMR 7.04(1)(f); the cell offers an email in its place.
3
At 11:42 a.m. the branch call log is counted
Branch 14 in Kettering sends its morning log: three calls about past-due payments, to Dolores Ybarrola, Kevin Mensforth and Grace Thompson. The contact counter matches each call to its debt by account number, then phone number. Dolores's count goes to 7 of 7. Kevin talked with the branch at 10:55 a.m. and promised $289.00 by October 16, so his conversation week starts and his 3 p.m. call comes off the plan; the freed slot goes to Ana Whitfield. Grace's count goes from 3 to 4 with no change.
Branch calls counted. Dolores's 2 p.m. call grays out and moves to a 6 p.m. email; Kevin's call comes off; the planner run lists each decision with its time.
4
Seven calls from two sources, on one record
Luis Ferradas, her collector, opens Dolores's account: 34 days past due, $612.40 past due, $14,820.55 balance. The call meter shows each of the seven calls with its source, six from the dialer and one from Branch 14, and states the next allowed call: Wednesday, October 14, when the October 7 call leaves the window. Her best call hours are early afternoon; her best email hours are 6 to 8 p.m.
One debt, seven calls. Every call about the loan from every team, the date the next call is allowed, and the day's decisions in order.
5
The email waits for the collector
The 6 p.m. email carries the past-due amount, a "Pay or set a date" link, the phone line and its hours, and a one-click opt-out. It waits for Luis to approve it. Below it sit consent and preferences with their sources: texts opted out August 22 (she replied STOP), email opens between 6 and 8 p.m., afternoons preferred, and time zone from area code 937 and her Dayton address, which agree. Her promise history shows the broken October 5 promise and two kept payments.
The email and the consent record. The message waits for the collector; each preference cites where it came from.
In the sample data, the plan has run since August 31: no call over any cap, and 15.2 promises to pay per 100 contacts against 12.4 in the twelve weeks before. The solution's design targets are zero calls over a limit with every team's calls counted, and 20% more promises to pay from the same contact budget, to be measured on your own book.
15 · Every screen
Twelve more screens: local-time blocks, a refused call, the count per debt, rule checks, tests, results and the exam log
In shortThe morning is the story. These screens show the rest: a Phoenix borrower's hours, a team lead moving a call, a collector's call refused during a conversation week, the count for every debt, the rule check, the state and city rules, strategy tests with control groups, results, the exam pack, the exam log and the settings.
Local hours. 9 a.m. on the floor is 6 a.m. in Phoenix, outside the local window, so no channel is allowed.
A team lead moves a call. Jordan Pike drags Ana Whitfield's call to 4 p.m.; the rules check the new cell before it is accepted.
A call refused. Kevin Mensforth talked with Branch 14 at 10:55 a.m., so a call now is refused until Tuesday, October 20, the end of his conversation week.
Contact counts. Every debt with its calls in the last seven days from all six sources, the limit in force and when the next call is allowed.
Check a contact. A 2 p.m. call to Dolores Ybarrola fails one line of the trace: 7 of 7 calls about this debt. The rule cards are the bank's own summaries. Regulation F presumes compliance at up to seven calls a week per debt and binds third-party collectors; this bank applies it to its own collectors as policy CP-7. The opt-out card's "within the hour" is the bank's setting: Regulation F requires an opt-out method in every message, and the TCPA allows up to ten business days to honor a revocation.
State and city rules. Massachusetts, Washington and New York City, each with its citation and today's count. The New York City card is the bank's summary: the rule counts per account, leaves mailed letters out of the count, and also bars contact after the borrower responds within the week; it reaches a lender once collection procedures start.
Strategy tests. Three tests against random control groups, with promises, contacts per promise, complaints and opt-outs, including the numbers that got worse. The strategy manager approves, declines or extends each one. Figures are sample data.
Results. Promises per 100 contacts by week before and after go-live, calls over a limit by month, when borrowers answer by weekday and local hour, and the channel mix. Sample data.
The exam pack. September's 38,412 entries checked against each rule, opt-out timing, and a random sample of 60 accounts, waiting for Helen Strand's signature.
The exam log. Every block, contact, count change, opt-out and plan change with its rule and who acted, from the branch call at 11:31 a.m. to the refused call at 11:46 a.m.
Your contact policy. Which limits apply, the local hours, how fast an opt-out is honored, and which sources count, set by compliance.
Who does what. Collector capacity, the self-cure threshold, email approval, and each person's role, from the team lead who moves contacts to the analyst who signs exam packs.
Select any screen to open it larger. The bank, borrowers, people and figures are fictional.
16 · Planning and sign-offs
Six agents count, check, score and plan; collectors place every contact and named owners approve changes
In shortEach agent has one job and limits it cannot cross. None of them places a call, sends a message, changes a rule or adopts a strategy. Collectors place calls and approve each collection email, the team lead moves planned contacts, the strategy manager approves strategy changes on tested evidence, and the compliance analyst owns the rules and signs the exam pack.
Counter, checker, scorer, planner, analyst and log keeper: one job each
Contact counter
Reads every call, text, email and letter from the dialer, branch logs, the reminder line, the letters vendor and outside agencies, and keeps the live count per debt: calls in seven days, the last conversation, opt-outs and stated inconvenient times.
Never places, changes or deletes a contact; a record it cannot match to a debt goes to a person.
Rules checker
Checks every hour and channel of every account against Regulation F, state and city limits, opt-outs, stated inconvenient times and stops, judging local time from both the area code and the address.
Never overrides a block; where sources disagree, the stricter reading wins.
Reach scorer
Scores how likely each borrower is to answer, and to promise, by hour and channel, from the account's own contact and payment history and its segment; scores the chance of paying unaided for accounts under 30 days.
Never uses protected characteristics; shows the records behind each score.
Contact planner
Builds each collector's plan at 8:00 a.m. Eastern within 28 calls an hour, skips accounts likely to pay unaided with one reminder, and re-plans when a count changes, filling a freed slot with the next best account.
Never plans a forbidden cell, and never contacts anyone.
Strategy analyst
Designs champion/challenger tests with a random control group, measures promises per 100 contacts, contacts per promise, complaints and opt-outs, and proposes a change only when the result holds for four weeks.
Never changes a strategy; reports the numbers that got worse alongside the ones that improved.
Exam log keeper
Writes every contact, block, count change and opt-out to the exam log with the rule, the source record and who acted, and builds monthly exam packs with totals, exceptions, opt-out timing and samples.
Never edits a past entry; the compliance analyst signs every pack.
Who places a contact, moves it, changes the strategy and owns the rules
Places each contactCollectorCalls whom the plan says, when it says, approves each collection email before it goes, records promises and hardship flags.
Changes the planTeam leadMoves planned contacts between cells; a forbidden cell refuses the move with its rule.
Changes the strategyStrategy managerApproves, declines or extends a tested change, seeing the control group's numbers beside it.
Owns the rulesCompliance analystChanges limits and rules, owns the exam log, signs the monthly exam pack.
Every contact, block, count change, opt-out and plan change is written once to an append-only log and kept for seven years. Agent steps and human decisions are recorded separately, with names and times.
Jordan Pike's Team 2 and the owners of its plan
Fictional, from the sample data
JP
Jordan Pike · collector team lead, Team 2
Eight collectors, 486 accounts on today's plan.
"By ten o'clock the spreadsheet is wrong; a branch or the agency called someone I didn't see."
LF
Luis Ferradas · collector
Works the plan, places calls and records promises.
"Tell me whom to call and when. Don't let me make the eighth call."
IO
Imani Okoro · collections strategy manager
Owns segments, channel mix and tests.
"I want more promises from the same contacts, and the evidence before I change anything."
HS
Helen Strand · collections compliance analyst
Owns the contact rules and the exam log.
"When the examiner asks why we called someone on day eight, I need the answer in one click."
17 · What goes in and out
Every team's contact records feed one count per debt, a ranked plan for each collector and an exam log
In shortThe solution reads the contact records your dialer, branches, text and email platforms, letters vendor and agencies already produce, applies your contact policy, and returns a ranked plan for each collector, a live count per debt with block reasons, tested strategy proposals and an exam log. Your systems of record stay where they are.
Contact records
Collections dialer attempts, answered or not
Branch and servicing-line call logs
Texts, emails, opens, replies and opt-outs
Letters sent
Outside agencies' daily contact files
Accounts and policy
Accounts, days past due, balances, promises and payments
Consent, preferences and stated inconvenient times
Federal, state, city and bank contact rules
Collector capacity and approval roles
Agents count, check, score and planEvery contact from every team, every hour and channel, under your contact policy
Collectors place every contact
Every block cites its rule
Outputs
Today's ranked contact plan for each collector, by hour and channel
A live count per debt with the limit in force and the next allowed contact
Strategy change proposals with control-group evidence
An append-only exam log and monthly exam packs
What changes for the team
The day's order is ready at 8 a.m.
A new branch or agency contact re-plans within minutes
Compliance answers "why this call" from one record
Branch and servicing phonesCall logs about past-due payments
Text and email platformsMessages, opens, replies, opt-outs
Letters vendorLetters sent per debt
Agency filesDaily contact files from placements
Loan and card systemsAccounts, delinquency, promises, payments
Consent recordsNumbers, consent, preferences
Identity and accessRoles, approvals, separation of duties
For each, check whether it has an API, a file feed, or only screens, how often it can send, and who owns it. A count is only as complete as the slowest feed.
Your dialer, branches and agencies keep working; their contacts join one count
Your dialer
Keeps placing calls. The plan sets whom and when; the dialer's attempts flow back into the count every minute.
Your branches and servicing lines
Keep calling their customers. Their logs are counted against the same debt as the collections floor's calls.
Your agencies
Send the daily contact files they already produce; their contacts count toward each debt the same way.
Your contact policy
Becomes settings: which limits apply, the local hours, how fast opt-outs are honored, which sources count.
Your strategy tests
Run against random control groups, with the evidence kept beside each approved change.
Your examiners
Receive packs that tie every contact and block to a rule and a source record.
The three rules behind every day's contact plan
1
Every team's contacts count
The dialer, branches, reminder lines, texts, emails, letters and agencies, per debt, before anyone dials.
2
The stricter rule wins
Federal, state, city and bank policy together; area code and address together.
3
Agents plan; people contact
Collectors place calls and approve messages; strategy and rule changes need their named owners.
Part C · Are you ready to automate?
Automating the collections contact plan: what over-contact costs, what a better plan returns, and how to test one
You run a collections floor, set its strategy, or answer for its contacts to examiners. This part is written for you: what over-contact and mistimed contact cost today, what planning contacts by rule and by hour could return, whether your data is ready, what to ask any vendor of contact strategy software, including us, and how to run a fair test.
18 · What over-contact costs
What over-contact and mistimed calls cost a collections floor: settlements, complaints and wasted dials
In shortThe visible costs are settlements and findings, and they can be large. The everyday costs are quieter: dials that reach nobody, calls spent on borrowers who would have paid anyway, team-lead hours spent rebuilding the day, and the complaint that arrives after the eighth call. Most of these are in your own data, and a week of counting finds them.
$75M
agreed by Capital One and three collection agencies in 2014 to settle claims over autodialed collection calls to cell phones without consent.31
Largest TCPA settlement at the time
$7.6M
settlement between the Massachusetts attorney general and an auto lender in 2023, over collection practices including excessive collection calls.32
$5.5M debt relief, $2.1M penalties
$22.61/hr
median wage of a bill and account collector in 2025, before benefits and overhead; 160,200 people do the job.38
BLS data via O*NET
Every point of answer rate cuts the dials each promise costs
Dials needed for one promise to pay, if 40% of conversations end in a promise
5% of dials reach the borrower50 dials
10% of dials reach the borrower25 dials
15% of dials reach the borrower16.7 dials
20% of dials reach the borrower12.5 dials
Illustrative · replace with your own numbers · Dials per promise = 1 ÷ (answer rate × promise rate per conversation). Use your own rates.
Show the numbers
Answer rate
Dials per promise
5% of dials reach the borrower
50 dials
10% of dials reach the borrower
25 dials
15% of dials reach the borrower
16.7 dials
20% of dials reach the borrower
12.5 dials
What nobody publishes. There is no public figure for the cost of a collection call, the share of calls placed by branches and agencies that never reach the collections count, the share of early accounts that pay unaided, or the promise-to-pay gain from planning by hour. Vendor figures for these come without a dataset. Measure your own.
Where over-contact hides in your dialer, branch and agency records
Cost
Where it hides
How to find your number in a week
Hidden calls
Branch phones, servicing and reminder lines, agencies
Pull one week of every source, match to debts, and count debts where the combined count passed 7 (or 2 in Massachusetts)
Wasted dials
Calls at hours borrowers never answer
Right-party contact by local hour from three months of dialer data, with the denominator stated
Calls to borrowers who pay anyway
Day 1–10 call campaigns
Share of called accounts that paid within ten days against a small uncalled group
Team-lead time
Rebuilding the order and chasing other teams' calls
Ask three team leads to log their planning minutes for a week
Complaints and opt-outs
Frequency, time and channel complaints
Complaints and opt-outs per 1,000 accounts by channel, last twelve months
Exam and audit time
Reconstructing why a call was allowed
Hours spent on the last exam request about call frequency or timing
What over-contact costs beyond the calculator
The borrower who stops answeringToo many calls teach a borrower to ignore your number, just when a hardship plan could help.
The account that rollsA call spent on someone who would have paid is a call unavailable for someone about to fall behind.
Call-blocking labelsHigh-volume dialing raises the chance carriers label your numbers as spam, which lowers answer rates for everyone.
Your agency's exposureYour agency is bound by Regulation F; your branch calls about the same debt still shape what borrowers experience.
The answer you cannot giveAn examiner asks why a borrower was called on day eight, and the records sit in four systems.
19 · Your return
Promises per contact and team-lead hours: estimating the return on a rule-aware contact plan
In shortTwo numbers carry the case: how many more promises to pay the same contacts produce, and how many team-lead hours stop going into rebuilding the day. Put in your own volumes and rates; every default marked illustrative is an assumption, and the 20% lift is the solution's design target, to be measured in a pilot.
Promises, kept cash, lead hours and exams: where a contact plan pays
Promises
More promises from the same contacts
Contacts land at the hour and channel each borrower answers, and accounts likely to pay unaided get one reminder.
contacts × promise rate × lift
Cash sooner
Promises that are kept
More kept promises bring past-due cash in earlier and keep accounts out of the next bucket.
extra promises × kept rate × average promise
Team-lead time
A plan ready at 8 a.m.
The order, counts and blocks are built before the floor opens and re-planned as contacts land.
team leads × hours saved a day × working days × hourly cost
Compliance
No eighth call
Every team's calls counted per debt, and the stricter rule applied, before anyone dials.
calls over a limit found in a look-back, before and after
Exams
One record per contact
Each block and contact tied to its rule and source, packed monthly.
hours to answer an exam request on frequency or timing
Borrowers
Fewer contacts, better timed
Fewer frequency complaints and opt-outs, measured per 1,000 accounts.
complaints and opt-outs per 1,000 accounts, before and after
Extra promises to pay and team-lead hours on your contact volume
Every input marked illustrative is an assumption to replace with your own figure. A collector's median wage is $22.61 an hour before benefits;38 a team lead's loaded hourly cost is higher.
Your volumeYour promisesYour team leads
Illustrative yearly value
Promises to pay a year today0
Extra promises a year0
Extra past-due dollars paid on kept promises$0
Team-lead hours released a year0
Those hours, valued$0
Hours valued, after your yearly cost$0
Formulas, per year: Promises today = contacts a month × 12 × promises per 100 ÷ 100 Extra promises = promises today × lift ÷ 100 Extra dollars paid = extra promises × kept share ÷ 100 × average promise Hours released = team leads × hours saved a day × working days After your cost = hours released × hourly cost − yearly cost
Extra dollars paid are past-due payments brought forward, not profit; the saving is the share of those accounts that would otherwise have rolled and charged off, which your roll rates estimate. Not counted: complaints and opt-outs avoided, exam hours, and calls over a limit that no longer happen. A lift of 20% is the solution's design target; your pilot measures the real one.
The lift your pilot measures decides most of the value
Extra past-due dollars paid on kept promises a year, at the calculator's default inputs
5% more promises$291.6K
10% more promises$583.2K
20% more promises (design target)$1.2M
Illustrative · replace with your own numbers
Show the numbers
Lift
Dollars a year
5% more promises
$291.6K
10% more promises
$583.2K
20% more promises (design target)
$1.2M
At the defaults, 15,000 contacts a month at 12 promises per 100 is 21,600 promises a year. A 20% lift adds 4,320; at 60% kept and $450 each, that is $1,166,400 of past-due payments brought forward. Six team leads saving three hours a day release 4,500 hours, worth $180,000 at $40 an hour.
Start here20 · Readiness check
How ready your contact data is: counts across teams, consent records, time zones, tests and owners
In shortPick the answer closest to your floor today. Eight questions score 0 to 2; the last is for reflection. The meter adds up your score as you go, and each question says why it matters and what a strong answer sounds like.
1
Every contact counted
Can you count, per debt, the calls from your dialer, branches, servicing lines and agencies in one place?
Why it mattersThe federal limit counts calls per debt, whichever team places them; a dialer-only count misses the rest.1
A strong answer"Dialer and agencies daily; branches weekly. We know which sources are missing."
2
Consent and opt-outs
Are consent, opt-outs and refused channels recorded in one place, with where and when each was given?
Why it mattersA STOP must be honored within ten business days under the FCC's rule, and a refused medium closes at once under Regulation F.5,1
A strong answer"One consent record per number and address, fed by the text and email platforms within the hour."
3
Local time
Do you keep both the address and the area code for each borrower, and use the stricter window when they disagree?
Why it mattersRegulation F's commentary sets the window to hours convenient in every location your data suggests.2
A strong answer"Both, with the overlap applied, and stated inconvenient times kept per borrower."
4
Written contact policy
Is your contact policy written down, covering federal, state and city rules and your own limits, with an owner?
Why it mattersSoftware applies the rules it is given. Massachusetts, New York City and Washington differ from each other and from Regulation F.3,14,4
A strong answer"Policy CP-7, owned by collections compliance, updated for New York City in September."
5
Your baseline
Do you know your promises per 100 contacts, right-party contact rate with its denominator, roll rates and frequency complaints?
Why it mattersNo public US benchmark exists for most of these, so only your baseline can prove a change.
A strong answer"12.4 promises per 100 contacts, 19% right-party contact per account attempted, roll rates by product monthly."
6
Testing practice
Do strategy changes go through a test with a random control group before they are adopted?
Why it mattersSmall lifts need large groups, and changes adopted without a control group cannot be told apart from seasonality.
A strong answer"Every change runs champion/challenger for at least four weeks, sized in advance."
7
Feeds software can read
Can the dialer, text and email platforms, branch phones and agency files be read by software, and how often?
Why it mattersThe plan is only as current as the slowest feed; a branch file once a day leaves the afternoon exposed.
A strong answer"Dialer and messaging by API every minute, branch logs every 30 minutes, agencies daily."
8
Owners and model review
Is there a named owner for strategy, another for the rules, and a path for scoring models through model risk and fair lending review?
Why it mattersContact scores are models under the 2026 guidance, and collection procedures fall under Regulation B.29,13
A strong answer"The strategy manager owns tests, compliance owns rules, and model risk has reviewed our scores."
9
Vision · for reflection
If an examiner picked ten past-due borrowers tomorrow and asked why each call last week was allowed, what would have to be true for you to answer each in under a minute?
Why it mattersYour answer lists the gaps: missing sources, missing consent history, missing time zones, missing rule citations.
A strong answerA short, specific list, for example: "every team's calls in one count, consent with its source, and each block tied to a rule."
From counting every source to planning every team: what your score says
0–6
Explore
Count first: pull one week of every contact source, match it to debts, and see how many passed a limit. Write the contact policy down and name its owner before buying anything.
7–11
Ready to pilot
Run a measured pilot on one team: count every source, plan by hour, and compare promises, complaints and opt-outs against a random control group for six weeks.
12–16
Ready to implement
Plan every team and agency: every feed, your full rule set as settings, approvals by role, scoring models through model risk, and the exam pack your compliance team will sign.
21 · Questions for any vendor
What to ask a contact strategy vendor about counting, consent, local time and test evidence
In shortAsk every vendor the same questions, us included. The answers show whether the count is complete, whether the rules match yours, how consent and opt-outs flow, how scores are built and tested, and what evidence you keep.
Ask
A good answer
A warning sign
Counting
Which contact sources does the count include, and how fast does each arrive?
Dialer, branches, servicing lines, texts, emails, letters and agencies, each with its feed frequency
"We count what our dialer places"
Is the count per debt or per phone number?
Per debt, with student loans under one account number as one
Per number or per borrower only
What happens to a contact record it cannot match to a debt?
It goes to a person, and the account is treated cautiously meanwhile
Dropped, or matched by best guess
Rules
How do you handle both 7-in-7 prongs, including the conversation week and excluded calls?
Both prongs, unconnected and consented calls excluded, ringless voicemail counted
"Seven a week" with no conversation week
Which state and city rules do you apply, and to which callers?
Massachusetts with texts, Washington with its daily cell limit, New York City per account and after a response, with who each binds
Federal rules only
How is local time judged when the area code and address disagree?
The overlap of both windows, plus the borrower's stated times
The area code alone
Who can change a limit, and is the change recorded?
Compliance only, versioned, with the reason
Any administrator
Consent and channels
How fast does a STOP or an email opt-out stop every planned message to that number or address?
Minutes, well inside ten business days, with the confirmation text handled
A nightly batch
Are you ready for the FCC's revocation changes that take effect November 25, 2026?
A setting per message category, the opt-out method disclosed in every call and text, and a record of which category each STOP covered
"We'll see what the FCC does"
Do texts follow Regulation F's procedures, including the reassigned-number check?
Yes, with the database checked within the required window
Texts sent to any number on file
Scores and tests
What goes into the reach and self-cure scores, and what is kept out?
Account and contact history; protected characteristics and close stand-ins excluded and tested for
"Hundreds of variables"
Can our model risk team review the scores under SR 26-2?
Documentation, performance and change history provided
A black box
How are strategy tests designed and sized?
Random control groups, sized in advance, complaints and opt-outs reported
Before-and-after charts
Evidence and data
Can we see, for any contact, which rules it was checked against and why it was allowed?
Each contact and block with its rule, source record and time, in an append-only log
A dashboard of totals
Who places contacts and approves messages?
Your collectors; the software plans and checks
Messages sent automatically with no approval option
Where does borrower data stay, and does it train your models?
Kept in your environment and excluded from shared model training, in writing
Vague answers
We found no published independent comparison of contact strategy vendors as of October 2026. A shadow count on a week of your own contact files, and a controlled test on one team, compare any vendor with your current process.
22 · A pilot
A ten-week pilot: count one week of every source, then test the plan on one team against a control group
In shortCount before you plan: a shadow count of one week of every source shows how many calls passed a limit without anyone knowing. Then run the plan on half of one team's accounts against a random control half for six weeks, and decide on promises per 100 contacts, calls over a limit, and complaints and opt-outs.
Baseline two weeks: promises per 100 contacts, right-party contact with its denominator, roll rates, complaints and opt-outs, for one team.
Connect every source: dialer, branch logs, reminder line, text and email platforms, letters vendor and agency files.
Shadow count one week: match every contact to its debt and count the debts that passed a limit when all sources are counted.
Test six weeks: half of the team's accounts, chosen at random, on the new plan; the other half on today's strategy; same collectors and limits.
Decide on three numbers: promises per 100 contacts, calls over a limit, and complaints and opt-outs per 1,000 accounts.
A ten-week pilot ends with a decision on three numbers
Your teamVendor
Baseline measures for one team
Connect every contact source
Load your contact policy and approvals
Shadow count of one week
Controlled test: plan against control
Read results and decide
Week 0246810
Illustrative · replace with your own numbers
Show the numbers
Activity
From
To
Baseline measures for one team
0
2
Connect every contact source
0
2
Load your contact policy and approvals
1
3
Shadow count of one week
2
3
Controlled test: plan against control
3
9
Read results and decide
9
10
Hidden calls, promises per 100 contacts and opt-outs: scoring the pilot
Measure
How
Why
Hidden calls
Debts over a limit in the shadow count that the dialer-only count missed
The compliance case in one number
Promises per 100 contacts
Test half against control half, with the uncertainty
The value case
Kept promises and roll rate
Kept within the promised date; bucket moves at month end
Promises that break are delays
Complaints and opt-outs
Per 1,000 accounts by channel, both halves
The borrower's side of the result
Team-lead minutes
Planning minutes logged before and during the test
The time case
The full working-session questions: 18 questions in six groups
Bring collections strategy, team leads, compliance, branch operations, agency management, model risk and IT into one room. Each question says why it matters, what a strong answer looks like, and the warning sign.
A
Early-stage volume and who gets a call
A1
How many accounts enter early-stage collections a month, by product and bucket?
Why it mattersSets the size of every test.
Strong answer · warning sign
Counts by product and bucket.
One total for the floor.
A2
What share of called accounts in days 1–10 would have paid without a call?
Why it mattersCalls to them are spent allowance.
Strong answer · warning sign
Measured against a small uncalled group.
"Everyone needs a call."
A3
Which segments go straight to a person: hardship, disputes, bankruptcy, military service?
Why it mattersThose accounts leave the automated plan.
Why it mattersTheir calls count against the same debt.
Strong answer · warning sign
A list with each system's owner.
"Only collections calls."
B2
How quickly can each source send its contacts?
Why it mattersThe slowest feed sets the exposure window.
Strong answer · warning sign
Minutes to hours.
Weekly reports.
B3
How do we match a branch call to the right debt when a borrower has two loans?
Why it mattersThe count is per debt.
Strong answer · warning sign
Account number on the log.
Name only.
C
Your 7-in-7 policy and the stricter local caps
C1
Do we apply 7-in-7 to our own collectors, and is that written?
Why it mattersIt is policy for a first-party lender, and examiners read policies.
Strong answer · warning sign
Written, with the conversation week.
"Our dialer handles it."
C2
Which of our borrowers live in Massachusetts, Washington and New York City?
Why it mattersTheir limits are lower than seven.3,14,4
Strong answer · warning sign
Counts by location, rules applied.
Unknown.
C3
When does a New York City account enter "debt collection procedures" in our systems?
Why it mattersIt triggers the city rule for a lender.4
Strong answer · warning sign
A flag when statements stop or the balance is accelerated.
No flag.
D
Consent records, STOP replies and email timing
D1
Where is consent for each number recorded, and how was it given?
Why it mattersCourts may now read consent afresh.23
Strong answer · warning sign
Per number, with source and date.
Assumed from the application.
D2
Does a STOP to a fraud alert stop collection texts today?
Why it mattersFrom November 25, 2026 a STOP to an informational message may cover only that kind of message; decide which categories stay separate and write it down.6
Strong answer · warning sign
A decision and a switch.
Nobody knows.
D3
Do our emails carry an opt-out and go out only between 8 a.m. and 9 p.m. local?
Why it mattersExaminers found reminder emails before 8 a.m.10
Strong answer · warning sign
Checked at send time.
Scheduled overnight.
E
Contact scores, fair lending and control groups
E1
Which scores decide who is called, and has model risk reviewed them?
Have we tested whether treatments differ by protected class?
Why it mattersCollection procedures are part of the credit transaction.13
Strong answer · warning sign
A yearly test with results.
"We don't use race."
E3
What was our last strategy change, and what was its control group?
Why it mattersShows whether tests are the habit.
Strong answer · warning sign
Named test, sized, with results.
A before-and-after chart.
F
If every contact were planned by the hour
F1
What if every collector's day were planned by hour before 8 a.m.?
Why it mattersTests the appetite for planning over list dialing.
Strong answer · warning sign
"Leads would coach instead of rebuild lists."
"Collectors know best whom to call."
F2
What if every branch call counted against the debt within the hour?
Why it mattersLinks branches to collections.
Strong answer · warning sign
"Branches would see the count too."
"Branches are out of scope."
F3
Which decisions would we never let software make?
Why it mattersShows where people stay.
Strong answer · warning sign
Placing calls, hardship, disputes, rule changes.
"All of it."
23 · Frequently asked questions
Contact strategy questions answered: 7-in-7, texts, calling hours, Massachusetts, New York City and the FCC's opt-out rules
In shortThe questions collections teams and buyers search for most, each answered on its own.
What is a collections contact strategy?
A collections contact strategy is the set of rules a lender uses to decide which past-due borrowers to contact each day, by which channel, at what local hour and how often. It weighs the risk that an account falls further behind and the chance it pays unaided against federal, state and city contact limits and each borrower's consent and preferences. Good strategies are tested against random control groups before they change.
What is the 7-in-7 rule in debt collection?
Under Regulation F, 12 CFR 1006.14(b), a debt collector is presumed to comply with the ban on repeated calls if it calls about a particular debt no more than seven times in seven consecutive days and not at all for seven days after a phone conversation about that debt. Exceeding either creates a presumption of a violation. Both presumptions can be rebutted, and the rule has applied since November 30, 2021.
Does the 7-in-7 rule apply to banks collecting their own loans?
Usually not directly: Regulation F applies to debt collectors under the Fair Debt Collection Practices Act, which mostly excludes creditors collecting their own debts. Banks remain subject to the federal ban on unfair, deceptive or abusive practices, to Regulation B, and to state and city rules such as Massachusetts' and New York City's that name creditors. Many banks apply the 7-in-7 limits to their own collectors as written policy.
Do text messages and emails count toward the 7-in-7 rule?
No. Regulation F's call count covers telephone calls, including ringless voicemails, and its commentary says placing a call does not include sending an electronic message. Texts and emails must still follow Regulation F's rules on timing, opt-outs and refused channels, and they do count under Massachusetts' two-per-week rule (texts) and New York City's three-per-week rule (any medium).
What time can debt collectors call?
Under Regulation F, contacts before 8 a.m. or after 9 p.m. local time at the consumer's location are presumed inconvenient, and so is any time the collector knows is inconvenient for that person. When an area code and an address suggest different time zones, the safe window is the hours convenient in both. New York City and Massachusetts use 8 a.m. to 9 p.m. Eastern, and Washington bars calls at home between 9 p.m. and 7:30 a.m.
How many times can a debt collector call in Massachusetts?
Massachusetts' 940 CMR 7.04(1)(f) allows no more than two telephone communications, including texts and recorded messages, in each seven-day period per debt to the debtor's home, cell or personal number, and two in each 30 days to other numbers. It applies to creditors collecting their own debts as well as to collectors. The state's highest court held in 2018 that unanswered automated calls can count.
What is New York City's 2026 debt collection contact limit?
Since September 1, 2026, New York City treats more than three communications or attempts in seven consecutive days per account, by any medium, as excessive, and any contact after the consumer has responded within that period. Mail, consumer-initiated contacts and unconnected attempts are excluded, and the hours are 8 a.m. to 9 p.m. Eastern Time. It covers collectors, and original creditors once they stop sending statements, threaten legal action or accelerate the balance.
What happened to the FCC "revoke all" rule?
It was the part of the FCC's 2024 consent rule that would have made a STOP to one kind of robocall or robotext end all later robocalls and robotexts from the same caller, and it was waived, finally to January 31, 2027. An FCC order released October 1, 2026 (FCC 26-67) replaces it from November 25, 2026: a STOP to an informational message may be treated as covering only that category, and callers may designate one disclosed, exclusive way to opt out. The FCC is still asking whether to require a one-step option to stop everything.
How fast must a lender honor a STOP text?
Under the FCC's rule, a revocation of consent, including replying STOP, must be honored within a reasonable time not exceeding ten business days; that limit stays when the FCC's November 25, 2026 changes take effect. One confirmation text is allowed and is presumed acceptable if sent within five minutes. Many lenders stop messages within minutes, and Regulation F also requires a simple opt-out method in every collection email and text.
What is a good right party contact rate in collections?
There is no public US benchmark. A 2024 survey of UK collection contact centers put the mean right-party contact rate at 26%, and US agencies report falling contact rates because of call blocking and spam labels. The rate depends on the denominator (dials, connected calls or accounts attempted), so compare your own rate over time, by hour and channel, with the denominator stated.
What is a roll rate in collections?
A roll rate is the share of accounts in one past-due bucket that move to the next bucket a month later. If 230 of 1,000 accounts that were 1–29 days late are 30–59 days late a month later, the roll rate is 23%. Multiplying roll rates through the buckets estimates how many accounts will reach charge-off, which comes at 120 days past due for closed-end loans and 180 days for cards under the federal retail credit policy.
How do you run a champion/challenger test in collections?
Write one change for one segment, choose the measures in advance (promises per 100 contacts, kept promises, roll rate, complaints, opt-outs), and split accounts at random between today's strategy and the change. Run both for four to eight weeks under the same limits, then compare against the effect size you set in advance. On a 12% promise rate, detecting a one-point lift needs about 17,000 accounts on each side.
Can AI decide whom collectors call?
Software can score and rank accounts and plan contacts within every limit, and studies show that a personal conversation and reminders that name a person raise repayment. The scores are models under the April 2026 model risk guidance and part of the credit transaction under Regulation B, so they need documentation, testing and a fair lending review. People should still place calls, approve message content, handle hardship and disputes, and approve rule and strategy changes.
24 · One-page summary
Collections contact strategy on one page: the limits by channel, the evidence, the tests and 13 terms
Print this page
In shortThe whole guide on one screen: the method, the rules as of October 2026, the readiness bands and the terms.
The method
Segment early-stage accounts by risk of rolling, chance of paying unaided and reachability.
Count every contact per debt from every team and agency, including branches.
Apply the stricter of Regulation F, state, city and bank rules; area code and address together.
Put each contact in the channel and local hour the borrower responds to; one reminder for likely self-cures.
Honor opt-outs and refused channels at once; keep consent with its source.
Test changes against a random control group; decide on promises, complaints and opt-outs.
Readiness: score 0–2 on eight questions: 0–6 explore · 7–11 pilot · 12–16 implement.
As of October 2026: Regulation F 7-in-7 and conversation week in force since November 30, 2021 · Massachusetts 2 per week incl. texts, creditors covered · Washington 3 a week, twice a day to a cell · New York City 3 per account per week, any medium but mail, from September 1, 2026 · FCC revocation rules from April 11, 2025; revoke-all replaced from November 25, 2026 by category-scoped STOPs and an optional exclusive opt-out method · courts not bound by FCC readings since June 20, 2025 · CFPB Bulletin 2013-07 withdrawn May 12, 2025 · SR 26-2 replaced SR 11-April 7 17, 2026.
13 terms
Contact strategy
Whom to contact, by which channel, at what hour, how often.
Early-stage collections
Roughly the first 90 days past due, before charge-off or placement.
Right-party contact
A conversation with the borrower or someone allowed to discuss the debt.
Roll rate
Share of a bucket that moves to the next bucket a month later.
Self-cure
An account that pays without a collection conversation.
7-in-7
Regulation F's presumption: up to seven calls per debt in seven days.
Conversation week
Seven days from a phone conversation in which further calls are presumed harassing.
Particular debt
Each debt in collection; the unit the federal count uses.
Limited-content message
A voicemail with only the content Regulation F lists; it falls outside the rule's definition of a communication.
Opt-out notice
The statement of a simple way to opt out that every collection email and text must carry.
Revocation of consent
A borrower's withdrawal of TCPA consent, by any reasonable means, or from November 25, 2026 by the caller's disclosed exclusive method.
Champion/challenger
Today's strategy and a change, run on random halves.
Promises per 100 contacts
Promises to pay ÷ contacts × 100; what each contact buys.
25 · Sources
Sources
Accessed October 2026. Regulatory status statements are as of October 2026.
CFPB, Regulation F, 12 CFR 1006.14 (harassing, oppressive or abusive conduct; telephone call frequencies) with official interpretation, read October 31, 2026. consumerfinance.gov
CFPB, Regulation F, 12 CFR 1006.6 (communications in connection with debt collection; inconvenient times; electronic communications and opt-outs) with official interpretation, read October 31, 2026. consumerfinance.gov
Massachusetts Office of the Attorney General, 940 CMR 7.00, Debt Collection Regulations (7.03 definitions; 7.04(1)(f) and (g)). mass.gov
New York City Department of Consumer and Worker Protection, Notice of Adoption of Final Rules Relating to Debt Collectors (6 RCNY 5-76 and 5-77), February 2026, effective September 1, 2026. rules.cityofnewyork.us
Federal Communications Commission, Report and Order and Further Notice of Proposed Rulemaking, FCC 24-24, CG Docket No. 02-278, released February 16, 2024 (revocation of consent; rule text for 47 CFR 64.1200(a)(10)–(12)). docs.fcc.gov
Federal Communications Commission, Report and Order and Further Notice of Proposed Rulemaking, FCC 26-67, CG Docket No. 02-278, adopted September 30, 2026, released October 1, 2026 (47 CFR 64.1200(a)(10)–(12) as revised; effective 30 days after Federal Register publication, 91 FR 67214, October 26, 2026, so November 25, 2026). docs.fcc.gov
C. Laudenbach and S. Siegel, "Personal Communication in an Automated World: Evidence from Loan Repayments", SAFE Working Paper No. 428, September 2024. safe-frankfurt.de
D. Karlan, M. Morten and J. Zinman, "A Personal Touch: Text Messaging for Loan Repayment", Yale Economic Growth Center Discussion Paper No. 1011, March 2012 (published in Behavioral Science & Policy, 2016). ageconsearch.umn.edu
CFPB, "Consumer Experiences with Debt Collection: Findings from the CFPB's Survey of Consumer Views on Debt", January 2017 (2,132 responses). files.consumerfinance.gov
CFPB, "Supervisory Highlights: Servicing and Collection of Consumer Debt", Issue 34, Summer 2024 (July 2024). files.consumerfinance.gov
CFPB, Fair Debt Collection Practices Act Annual Report 2025, November 2025 (complaints received in 2024). files.consumerfinance.gov
Washington State Legislature, RCW 19.16.250 (prohibited practices of collection agencies), as amended 2025. app.leg.wa.gov
FFIEC, "Uniform Retail Credit Classification and Account Management Policy", 65 FR 36903, June 12, 2000. govinfo.gov
CFPB, "Debt Collection Practices (Regulation F)", final rule, 85 FR 76734, November 30, 2020, effective November 30, 2021, including the section 1022(b) analysis of calling data at 85 FR 76870–76872. govinfo.gov
CFPB, "Debt Collection Practices (Regulation F)", final rule, 86 FR 5766, January 19, 2021, effective November 30, 2021. govinfo.gov
CFPB, "Interpretive Rules, Policy Statements, and Advisory Opinions; Withdrawal", 90 FR 20084, May 12, 2025 (item 32: Bulletin 2013-07). govinfo.gov
Alston & Bird, "What Counts as an Attempt to Contact a Debtor", March 28, 2019 (on Armata v. Target Corp., Massachusetts Supreme Judicial Court, 2018). alston.com
Federal Communications Commission, Consumer and Governmental Affairs Bureau, Order DA 26-12, January 6, 2026 (extends the waiver of the revoke-all requirement in 47 CFR 64.1200(a)(10) to January 31, 2027; superseded by FCC 26-67 from November 25, 2026). docs.fcc.gov
Supreme Court of the United States, docket No. 23-1226, McLaughlin Chiropractic Associates, Inc. v. McKesson Corp., decided June 20, 2025. supremecourt.gov
Nightingale v. National Grid USA Service Co., No. 19-12341-NMG (D. Mass.), memorandum and order, August 4, 2020. govinfo.gov
V. Fedaseyeu and R. Hunt, "The Economics of Debt Collection: Enforcement of Consumer Credit Contracts", Federal Reserve Bank of Philadelphia Working Paper 18-04, revised October 2018 (working paper). philadelphiafed.org
X. Cadena and A. Schoar, "Remembering to Pay? Reminders vs. Financial Incentives for Loan Payments", NBER Working Paper 17020, May 2011. nber.org
J-PAL, evaluation summary of L. Haynes, D. Green, R. Gallagher, P. John and D. Torgerson, "Collection of Delinquent Fines: An Adaptive Randomized Trial to Assess the Effectiveness of Alternative Text Messages", Journal of Policy Analysis and Management 32(4), 2013. povertyactionlab.org
J. Fonseca, "Less Mainstream Credit, More Payday Borrowing? Evidence from Debt Collection Restrictions", Journal of Finance 78(1), 2023, pp. 63–103. ideas.repec.org
Board of Governors of the Federal Reserve System, SR 26-2, "Revised Guidance on Model Risk Management", April 17, 2026, issued jointly as OCC Bulletin 2026-13 and FDIC FIL-15-2026. federalreserve.gov
CFPB, Consumer Response Annual Report, January 1–December 31, 2025, March 2026 (section 4.2: about 387,400 debt collection complaints received in 2025). files.consumerfinance.gov
Kelley Drye, "Capital One Settles Largest TCPA Class Action for $75M", August 5, 2014. kelleydrye.com
Goodwin, "Massachusetts AG Enters Into $7.6 Million Settlement With Auto Dealer", February 8, 2023 (settlement with Toyota Motor Credit Corporation announced February 2, 2023). goodwinlaw.com
CFPB, Equal Credit Opportunity Act (Regulation B) final rule, 91 FR 21620, effective July 21, 2026 (disparate impact); challenged in NFHA v. CFPB, pending October 2026. govinfo.gov
Colorado General Assembly, SB26-189, Automated Decision-Making Technology, signed May 14, 2026, duties from January 1, 2027. leg.colorado.gov
Federal Reserve Bank of New York, Quarterly Report on Household Debt and Credit, 2026 Q2, and its data workbook (pages 3, 13, 14). newyorkfed.org
MaxContact, "Optimising Your Debt Collection Contact Centre Performance: 2024 UK Benchmarking Insights", 2024 (survey of UK collection contact centers). maxcontact.com
TrueAccord, "Declining RPC rates, rising consumer complaints", January 31, 2024, reporting ACA International member surveys. blog.trueaccord.com
O*NET OnLine, "Bill and Account Collectors" (43-3011.00), wages and employment from U.S. Bureau of Labor Statistics 2025 data and 2025–2035 projections. onetonline.org
Next step
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Explore the solution, or bring a week of your dialer, branch, text, email and agency contact files, and we will count them per debt with you, every block tied to its rule.
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