CFPB Issues Limited-Content Messages, Call Frequency FAQs

On October 1, 2021, the CFPB issued Debt Collection Rule FAQs on limited-content messages and call frequencies. The subjects of the call frequency FAQs are presumptions, excluded calls, and rebutting the presumptions.

More specifically, the FAQs provide information on the requirements for messages to be limited-content messages, including interplay with state law, dropped calls, pre-recorded voicemails, and using d/b/a’s. Additionally, the FAQs shed light on the types of calls and conversations that fall within the call-frequency presumption of compliance, including which calls are excluded from the frequency count, and factors of rebutting the presumptions.