The path to getting a higher education is a courageous decision that millions of Americans start each year when attending college. It sets the foundation for countless careers and drives personal growth that lasts a lifetime. However, education is expensive and paying back the loans can be challenging—an estimated 5.8 million student loan borrowers have delinquent accounts.
This number could get even higher with student loan forgiveness ending, interest on the debt resuming and shifts repayment options. Student loans and debt collection servicing have always shared a close relationship. And the current changes to the federal student loan system is primed to send shockwaves through debt collection services across the nation.
Learn how student loans have changed in 2025 and trends your business needs to look out for as the situation continues to evolve.
How Student Loans Have Changes in 2025
Before we dive into the implications for the debt collection industry, it’s important to understand some of the key changes recently made to federal student loans. The current administration signed into law the “One Big Beautiful Bill Act” on July 4th, 2025. This legislation overhauled the student loan system:
Student Loan Forgiveness Paused: Borrowers on SAVE plans are seeing the end of payment forgiveness. Right now, payments are required and accruing interest on loans restarted on August 1st, 2025.
Creation of Repayment Assistance Plan (RAP): RAP isan income-based plan for new borrowers that requires a minimum payment regardless of a person’s income level. This plan will only be approved for cancellation after 30 years of qualifying payments.
One of the biggest and most immediate effects that student loans will have on debt collection solutions is a surge of collection activity. With loan forgiveness paused, the millions of delinquent accounts are going to be subject to collection efforts. To start, the federal government is putting increased focus on accounts that are 60 days or more delinquent.
This means that standard debt collection communications channels like phone calls and physical mail are going to be much more crowded for the foreseeable future. It’s also likely that some customers your business talks to have this type of financial obligation. That means no matter what debt type you’re collecting, there is more competition to get their attention through non-digital channels and less funds available to repay debts.
We Could See An Increase in Involuntary Collection Tools
When a consumer defaults on their student loan debt, the federal government has strong tools to help them collect payments. After 270 days pass without a payment being made, the government can garish up to 15% of the borrower’s paycheck. Any federal tax refunds can also be withheld and applied to the loan.
Any student loan accounts that are in delinquency or have defaulted can also be reported to national credit bureaus, causing damage to the borrower’s credit score. Consumers who are going through this process may be less likely to make payments on other debts while they try to keep up with student loans. The common thread is that more student loan borrowers could have reduced disposable income once all the changes take effect.
New Student Loan Rules Could Lower Credit Scores
Experts agree that the new student loan rules have a strong possibility of lowering credit scores for existing borrowers. Since the payment forgiveness that started shortly before COVID is ending, borrowers will likely need time to make payments as other costly necessities (like the rise of grocery costs) take their attention.
It’s possible that this will have widespread effects on consumer credit scores, making it more difficult for these borrowers to participate in the financial system. Specifically for student loans, a lower credit score makes it harder for borrowers to consolidate the debt at an affordable interest rate.
A lower credit score also makes it more difficult to access new lines of credit, a common tactic consumers use to pay off debt. Borrowers with a lower credit score will get higher interest rates on new loans, making it more expensive to get loans and more likely that payments made on debts will be in smaller amounts. To help navigate this challenge, debt collection services that offer consumers more payment options could have greater success.
Increase Your Collections Performance with an Industry Leading Platform
Student loan debt is primed to have a lasting impact on debt collection solutions. If you want to leverage AI that adapts to these situational challenges to collect more from happier people, TrueAccord is here to help.
If you want to empower your debt collection solutions with machine learning and a consumer-friendly digital experience, contact our sales team today.
Despite economic uncertainty, Americans continue to spend, albeit what they’re spending on has shifted. After two consecutive months of reduced spending, consumers came back in June with purchasing focused heavily on necessities like clothing and personal care, rather than electronics or appliances. Discretionary spending also stayed strong on restaurants and bars, indicating that while consumers are feeling some amount of pressure from the economy, it hasn’t really hit their wallets just yet. But economists and key indicators are foretelling more financial challenges ahead, so consumer sentiment may not be keeping up with reality.
The debt collection industry is navigating a period of transformation via a combination of regulatory shifts, technological advancements and evolving economic pressures. Key developments continue to reshape collection strategies, compliance requirements and the tools used to recover outstanding debts. As you protect your bottom line in a rapidly evolving consumer financial landscape, let’s look at what you should consider as it relates to debt collection with an eye toward the second half of 2025.
Key Economic Indicators
After several months of speculation and fluctuation, inflation is starting to heat back up, potentially showing the first impacts of tariffs and signaling what’s ahead. Consumer prices rose 0.3% in June after rising 0.1% in May, pushing the annual CPI inflation rate higher to 2.7%, the highest since February. The increase was driven by higher gas prices and a broad assortment of goods showing the effects of businesses sharing higher import costs with consumers.
On the jobs front, the economy added 110,000 jobs in June. Looking at the number of jobs added through the first part of the year shows an average of 124,000 jobs per month, which is significantly lower than last year’s monthly average of 168,000. With layoff activity relatively low and wage growth remaining decent, economic uncertainty has slowed the pace of hiring and created a somewhat stagnant employment market.
The Federal Open Market Committee held rates steady at 4.25-4.50% at their meeting in mid-June, and Wall Street economists are predicting the central bank to continue their wait-and-see approach at their next meeting in July given June’s reported CPI and expected PCE inflation increases. Bets are now on a September rate cut if the inflation threat cools and the jobs market weakens more noticeably.
The Federal Reserve Bank of New York’s latest Quarterly Report on Household Debt and Credit for Q1 2025 showed that total household debt in the US reached $18.20 trillion, a $167 billion or 0.97% increase from the prior quarter. This growth was primarily driven by increases in student loan and mortgage balances, while credit card and auto loan balances decreased. The report showed delinquency rates rising, with 4.3% of outstanding debt in some stage of delinquency, the highest level since the beginning of 2020.
Mortgage loans experienced a significant rise in early and mid-stage delinquencies across all credit categories in May. Mortgage delinquencies increased to 1.03% from 0.92% the previous month, suggesting that the housing market might be showing initial indicators of financial strain among homeowners.
What’s Impacting Consumer Finances?
Just as more student loan delinquencies are reported and sent to collections, borrowers who had previously been granted an interest-free forbearance period under the Saving on a Valuable Education (SAVE) Plan will lose those benefits. On August 1, the administration will resume interest charges on the accounts of around 8 million borrowers as the SAVE program and several other income-driven payment options end. Overall, the change will see borrowers being charged more than $27 billion in interest over the next 12 months, which will have wide repercussions on students and families.
And in a reversal of a move by the Consumer Financial Protection Bureau (CFPB) earlier this year, a federal judge recently blocked a rule that would have removed unpaid medical debt from the credit reports of about 15 million consumers who carry a total of roughly $49 billion in medical debt. This financial burden could influence creditworthiness and access to loans for many.
What’s Impacting the Debt Collection Industry?
On the federal level, the CFPB has announced a new set of supervision and enforcement priorities for 2025. The bureau intends to reduce the number of its supervisory exams, focusing instead on cases of tangible consumer harm and actual fraud. While this may mean fewer routine audits for collection agencies, it signals more intense scrutiny on practices that directly and negatively impact consumers, with a continued focus on areas including mortgages, credit reporting, and FCRA and FDCPA violations.
In June, the CFPB also published a policy statement in the Federal Register outlining its approach to addressing criminally liable regulatory offenses under statutes including the Consumer Financial Protection Act and Truth in Lending Act, among others.
In efforts to enhance efficiency, the debt collection industry is rapidly embracing new technologies, and artificial intelligence (AI) and digital communication platforms are at the forefront of this technological wave. AI is being leveraged more widely to personalize consumer engagement, predict payment likelihood, and optimize collection strategies. Meanwhile, digital channels like Rich Communication Services (RCS) are gaining traction as innovative methods for consumer contact, offering more interactive and self-service options.
However, the use of technology and collection tactics remains under the watchful eye of regulators. In a significant enforcement action in June 2025, the Federal Trade Commission (FTC) secured a permanent ban against a debt collection operation found to be using deceptive and harassing methods to collect on “phantom debts.” This action underscores the agency’s ongoing commitment to cracking down on illegal collection practices and serves as a reminder to the industry of the severe consequences of non-compliance.
How are consumers feeling about their financial outlook?
In analyzing consumer sentiment, it’s important to note that the following surveys relay responses may have been taken before the latest inflation figures were released, so there may be an incongruity in reporting.
The Fed’s June Survey of Consumer Expectations showed that households’ inflation expectations decreased at the short-term and remained unchanged at the medium- and longer-term periods. Unemployment job loss and household income growth expectations improved while spending growth expectations slightly declined. In general, households were more optimistic about their year-ahead financial outlook.
The latest University of Michigan consumer sentiment survey, reporting from mid-way through July, showed that Consumer sentiment ticked up about one index point to 61.8 from June, reaching its highest value in five months, but still 16% below December 2024 and its historical average. Expected personal finances fell back about 4%, with the report noting that consumers are unlikely to regain their economic confidence until they feel assured that inflation is unlikely to rise.
The Conference Board’s Consumer Confidence Index deteriorated by 5.4 points in June, falling to 93.0 from 98.4 in May. The report showed less positivity about current business conditions and job availability, as well as more pessimism about business conditions, job availability and income prospects over the next six months.
What Does This Mean for Debt Collection?
The debt collection industry in mid-2025 is at a pivotal juncture, tasked with balancing the adoption of powerful new technologies and navigating a challenging economic environment while adhering to an evolving regulatory framework. The ability to adapt to these concurrent trends will mean success for businesses in this sector. For lenders and collectors, here are a few things to keep in mind:
Consumers expect more in debt collection. Gone are the days of debt collection letters or calls from unknown numbers eliciting a productive response.Now, consumers want empathy, understanding and convenience in their financial matters. Keeping up with consumer expectations can mean the difference between collecting debt and not.
Self-service is one of those key expectations. Convenience by way of self-serving is a win-win for your business and consumers. Offering a comprehensive self-serve portal means consumers can engage whenever they want (even outside traditional FDCPA-regulated hours) and reduces resources needed to manage accounts and process payments.
Ready or not, AI is here. Technology is already transforming debt collection by changing the way lenders and collectors engage with consumers, and if you’re not getting on board, you’ll find your business soon left behind. The time to thoughtfully adopt AI is now. Not sure where to start? Here are the must-know tech terms to get you going.
As recently as 15 years ago, consumer expectations about the debt collection experience looked starkly different than they do today. Back then, people expected debt collection communications to come as a piece of physical mail, and consumers were more likely to answer the phone for an unknown number before spam calls and call labeling and blocking became the norm. Companies who were looking to collect on a debt often used aggressive tactics, and customer satisfaction wasn’t a priority as long as some of the money owed was recovered.
Now, consumers want empathy, understanding and convenience from the companies they interact with, especially in financial services. These shifts in consumer expectations continue to spark changes in debt collection trends and have led to more businesses investing in digital strategies to better engage with consumers. Join us as we take a more in-depth look at how consumer expectations in debt collection have changed and what it means for your business.
Customer Satisfaction is a Key Debt Collection Trend
Consumers today want their problems in financial matters resolved sooner rather than later. A recent survey done by TCN on consumer expectations found that financial companies are seeing a decline in customer satisfaction. One of the main drivers of this trend is people reporting that customer service efforts aren’t solving their problems effectively. A key benchmark used in this survey looked at how often financial service businesses were able to solve customer problems on first contact.
Only 13% of survey respondents said that their problem is always solved the first time they reach out. The more someone is forced to call back or wait for a follow up, the less likely they’ll be to engage with the company moving forward. For debt collection, that means fewer payments the longer a consumer has to wait. These survey findings stem from the debt collection trend of consumers wanting to fix problems on the spot. This notion is part of the reason why self-service portals and mobile apps have become the preferred method of resolving financial matters.
One key digital debt collection strategy is offering your customers more options that are easily accessible to them. In fact, 59% of consumers in debt want more flexible payment options. If your business is trying to improve its debt collection performance, giving your customers more options will often lead to higher levels of satisfaction. The proof of this digital debt collection trend can be seen with TrueAccord. Roughly 98% of TrueAccord customers resolve their debts with self-serve options and don’t ever interact with a human in the process.
Preferred Communication Channels for Bill and Debt Notifications Have Changed
Today, there’s no shortage of ways to send customers bills and debt notifications. For many companies out there, these notifications are sent through channels that are convenient and/or familiar to them, which doesn’t always align with consumer preferences. The more in-tune businesses are with consumer preferences, the more likely their communications will be engaged with. For businesses looking to recover debt, that means better collections performance and happier customers.
Let’s walk through an example. According to the same TCN survey, 47% of consumers prefer to be contacted by email for bill and debt notifications. Around 25% of Gen Z and 22% of Millennial customers prefer to be notified by push notifications through mobile apps. Your digital debt collection strategies need to take these expectations into account to maximize engagement. Even though email was the most desired communication method, every consumer is an individual with their own preferences.
Some of the best digital debt collection strategies leverage AI and machine learning to test and uncover the best channel for every individual. TrueAccord uses its patented machine learning engine Heartbeat that learns from every customer interaction to determine the best step to take with each consumer. It’s a personalized approach to debt collection where consumer expectations and preferences are at the core of every communication. The result is collecting more from happier people.
Convenience is King in Digital Debt Collection Strategies
In financial industries like banking and debt collection, convenience has emerged as one of the most important consumer preferences. With how critical messages in these industries often are, consumers want ways to be able to easily address them so the problem doesn’t linger and cause prolonged stress. For further proof of this trend, a recent survey by the American Bankers Association showed that 55% of consumers prefer mobile banking. Only 8% of people surveyed go to a physical branch for their banking needs.
The consumer trend of wanting more convenience through self-serve options is carried through into the debt collection industry. TrueAccord, for example, has been able to honor this consumer trend with its self-service portal. It’s a low friction way consumers use to pay off debt and should be a key strategy leveraged for digital debt collection.
Based on research done by McKinsey, consumers who digitally self-serve resolve their debts at higher rates and are much more likely to pay off the debt in full. Plus, the customer satisfaction is much higher with self-service portals compared to making a payment over the phone. These trends emphasize the importance of convenience. But just don’t take it from us, here’s what a real TrueAccord customer had to say:
“Thank you for being patient and for having a portal that makes it easy to make the payment without filling out a bunch of stuff and having to make an account or something.”
Stay On Top of Consumer Expectations in Debt Collection with TrueAccord
It can be challenging to stay on top of consumer expectations in debt collection. But with the right partner, your business can improve debt collection performance while increasing customer satisfaction.
TrueAccord is a leading digital debt collection agency that’s powered by machine learning to provide a consumer-friendly experience that honors their preferences. Schedule a consultation today to learn more about how our platform can handle your delinquency needs.
Credit unions are vital pieces of the communities they serve. They’re pillars of financial literacy that support the local economy by offering personalized service to members. Credit unions often need continued growth to not only stay competitive in the market, but to also better pursue their mission as an organization.
However, certain market factors like facing competition from large financial institutions can make it challenging for credit unions to thrive. The good news is that with the right approach, membership expansion is achievable. Learn five credit union growth strategies to help your business below.
1. Make Membership Engagement A Priority
One of the clearest paths to growth is for credit unions to get more members. And a good strategy to achieve that is to prioritize membership engagement. Some of the most successful credit unions leverage technology to have more points of contact with their members. Online touchpoints like accepting membership applications online, a strong social media presence and mobile apps (for mobile banking) all add value to customers.
Digital touch points make it easier for your credit union to introduce more convenience to your customers. The happier your members are, the more likely they are to share their experience, which often leads to membership growth.
2. Leverage the Potential of Your Unique Markets
At their core, credit unions operate with a relationship-based business model. This approach is one of the main motivations behind specialized services that serve niche markets. The question is, can your business do more in those unique markets? We’ll expand on this strategy by walking through an example.
Let’s say you’re a credit union that offers specialized loans for musical instruments. While the service is promoted, there’s more that can be done to gain more traction in the market. For starters, your team could reach out to local schools, music stores and teachers. A limited time promotion, sponsorship or contest could drive more customers to this core service.
3. Focus on Community Outreach
Community outreach and a credit union’s financial health often go hand-in-hand. Businesses that put extra focus on serving the community can see increased membership growth and loyalty. Some community outreach initiatives that credit unions could leverage include:
Free Community Events: Host financial literacy workshops that are free for members and the local community. You can also ask attendees about future workshops they’d like to see to help build an event calendar.
Sponsorships: Look for sponsorship opportunities in the local community. Whether it’s backing a little league team or partnering with a local non-profit, make sure the sponsorship aligns with your credit union’s mission.
Partner with Local Businesses: Look for other local businesses that focus on serving the community such as a local insurance agent. There’s a lot of opportunity to grow your credit union’s businesses by cross promoting services with them.
4. Update the In-Branch Experience
An approachable tech solution for credit union growth is to update the in-branch experience with digital signage. These signs are programmed to enhance the customer experience by displaying relevant information such as the current wait time, what documents are needed for specific services, finance tips, and more.
Digital signage also provides the benefit of being a brand ambassador for customers that keeps them engaged when they’re not working with an employee. Industry experts agree that digital signs are a key part of optimizing the branch experience for customers. Digital signs add value without removing the personal rapport expected at credit unions.
5. Embrace an Omni-Channel Approach to Debt Collection
Every credit union has delinquent accounts, and every dollar recouped is another dollar that can be re-invested in the community. An omni-channel approach to debt collection seamlessly combines each communication channel into a consumer-centric approach. The heart of this strategy is all about communicating through a customer’s preferred channel. Research shows that initiating contact with customers on their preferred channels can lead to a 10% increase in payments.
One bad interaction with a customer can damage your brand reputation. That’s why it’s important to provide a debt collection experience that caters to customer needs and preferences. With surveys showing that 46% of consumers expect to be contacted through their preferred channels, how can your credit union fully leverage digital debt collection?
TrueAccord Specializes in Digital Debt Collection for Credit Unions
At TrueAccord, our omni-channel approach is fueled by a patented machine learning engine called Heartbeat. It determines the right channel, to send the right message, at the right time, all while maintaining compliance.
If your credit union is looking to collect more from happier people, TrueAccord can help. Our platform can handle your credit union’s charged-off accounts with an approach loved by consumers. Contact our sales team today to learn how we can support your business goals.
New York City’s Department of Consumer and Worker Protection (DCWP) has been actively revising an amendment to their debt collection rules since November 2022. Multiple rounds of proposed amendments and public hearings have occurred, resulting in several revisions based on stakeholder feedback. In August 2024, DCWP published a notice of adoption of the final version of the amendment, initially effective December 1, 2024. Due to stakeholder confusion, requests for additional time, and a lawsuit filed by ACA International and Independent Recovery Resources, the DCWP extended the effective date to October 1, 2025. On April 10, 2025, the DCWP released additional changes to the amendments aimed to clarify “the applicability of rules to original creditors collecting their own debts, address trade practices and consumer protection concerns.” Any comments are due by June 10, 2025 and the amendment takes effect on October 1, 2025.
Though we have entered an era where digital communication is becoming the standard, New York City’s newly revised proposal still restricts debt collectors from using email and SMS without prior consumer consent. Additionally, the changes require original creditors, who already obtained consent to communicate electronically, to take additional steps after starting debt collection. While the changes are well-intentioned in their aim to “clarify the intent and applicability of recently adopted amendments” to the debt collection rules and ultimately address the industry concerns that resulted in a lawsuit over the first proposed amendment, the amendments still have the unintended consequence of making it more difficult for those who are struggling with debt to learn about and resolve their issues efficiently, effectively, and without added layers of frustration. Consumers, creditors, and collectors should all be concerned and seeking additional revisions.
Statistics and Court Rulings Reinforce the Benefits of Digital Consumer Engagement
In today’s world, 80% of consumers prefer a full digital banking experience, including when it comes to debt collection. Why? It’s simple: these communication methods are quick, convenient, and less intrusive. They allow consumers to engage with creditors or debt collectors on their own time, whether they’re at home, at work, or on the go—and it’s no surprise that 25% of consumers engage with emails after 9:00 pm and before 8:00 am.
Emails and SMS messages are particularly effective in reaching consumers who might not be available for a phone call or may be reluctant to open a letter. Email allows for easy documentation, while text messages offer a faster, less formal way to remind consumers of their debt obligations. This is why many consumers prefer these methods over phone calls, which can be disruptive and intrusive. The federal courts agree. A recent TrueAccord court victory in the Northern District of Illinois stated unequivocally that receiving an email about a debt is less intrusive to consumers than receiving a phone call. And a separate TrueAccord victory as email is silent unlike “noisy telephone rings.”
The Pitfalls of New York City’s Proposed Laws on Consumers
Despite statistics and court rulings, the New York bill in question would require debt collectors to get explicit consent before contacting consumers via text or email, limiting these convenient communication channels. While the law’s proponents argue that these measures are necessary to protect consumers from excessive communication, it overlooks the fact that the existing state and federal law already prohibits debt collectors from harassing consumers. It is illegal under existing New York City, New York state and federal debt collection laws to harass or communicate excessively thereby annoying consumers. The proposal ignores the significant benefits digital outreach provides consumers.
Digital communications are a step forward in consumer protection providing consumers with a written and documented record of communications. Digital channels offer protection from unwanted communication with easy ways to opt out. Email service providers launched one-click unsubscribe last summer, requiring senders to display a one-click unsubscribe button at the top of all emails. To opt-out consumers need only click on the one-click unsubscribe. Consumers can also mark emails as SPAM. When enough consumers take that action, the sender gets banned by the email providers. Consumers can just as easily reply STOP to opt out of SMS communications. The CTIA short code rules require senders to honor several different key word opt-outs and failure to do so results in suspension of the short code.
This proposed amendment ultimately makes it much harder to reach a consumer in the first place. Imagine being behind on payments and missing multiple calls from your creditor, only to later discover that you can no longer be contacted by email or SMS until you opt in. Requiring consent first introduces a significant hurdle. Getting a consumer to respond to a phone call at all (let alone to opt into email or SMS communication) is notoriously difficult, with 80% reporting they will block calls from unknown numbers, according to research from TransUnion. With that in mind, the New York law has the potential for many consumers to simply ignore the phone call to give their consent to be contacted digitally, and as a result, miss out on opportunities to resolve their debt.
This is problematic because the majority of consumers actually prefer digital communication with debt collectors. According to research, many debtors are more likely to engage with collection agencies when contacted by email or text message than by phone or traditional mail. The rise of these technologies has made it easier for people to manage their debts without feeling overwhelmed by the process. For consumers in New York, the proposed legislation could effectively take away a tool that could help them avoid debt-related anxiety, delays, and confusion.
The Pitfalls of New York City’s Proposed Laws for Business Operational Costs
Beyond consumer experience, the New York City proposed further amendment would negatively impact businesses’ bottom line. Studies have found that customers contacted digitally make 12% more payments than those contacted via traditional channels; this will be eliminated under the proposed amendment. Whether collecting in-house or using a third-party agency, the additional operational costs that go into traditional methods like outbound dialing and snail mail have always made initiating communication via digital channels a more cost-effective way to collect—an option that will no longer be afforded to New York City residents.
Even before the release of the additional amendments, businesses and agencies executing outbound call strategies and leveraging dialer technologies faced the reality that 49.5% of consumers take no action after a collection call—and, again, that’s if you can actually get a customer to answer the phone.
And for collectors relying on physical letters to make contact or gain consent, the process is even slower and easily ignored or lost by the consumer—and more costly for the business. Sending letters has become significantly more expensive with the cost of a single paper letter often exceeding 75 cents, depending on the number of pages per letter and volume. If you then take into consideration that contacting first through a customer’s preferred channel can lead to a more than 10% increase in payments and 59.5% of consumers prefer email as their first choice for communication—snail mail isn’t just expensive thanks to the price of paper and stamps, but it can also negatively impact repayment rates from late-payers who prefer digital contact.
NYC Residents Should Receive the Same Digital Communications Benefits All Non-NYCers Receive
The primary goal of these regulations should not be to ban digital communication methods, but rather to regulate them in a way that safeguards consumers from harassment while maintaining their access to modern, efficient forms of communication. Digital communication offers consumers more control over how and when they are contacted, with email and text message platforms incorporating built-in features like unsubscribe options and opt-out mechanisms to prevent unwanted communication. New York City’s stricter rules would leave consumers at a disadvantage, especially those who are less likely to answer phone calls.
In contrast, the rest of the country allows consumers to receive important information about their debts through digital means without additional barriers. For consumers outside New York City, debt collectors can proactively send communications through email and text, as long as these messages include clear opt-out options, such as “reply STOP” for text messages or unsubscribe links for emails. Strict penalties exist for failure to honor opt-out requests, ensuring that consumers retain the ability to control their communication preferences. Furthermore, digital communications in these areas are subject to the same frequency limitations as traditional methods under the Fair Debt Collection Practices Act (FDCPA) and Regulation F, which means consumers still have protections against excessive or harassing contact.
The overwhelming preference for a full digital banking experience, as mentioned above, means many consumers already opt-in and communicate through primarily digital channels with their creditors. Requiring consumers who have already opted-in to have to again opt-in to digital communications in order to discuss the same account with a collection agency adds burden to consumers. When a consumer provides their electronic contact information (email address or cell phone number) to the creditor, there should be little doubt that the consumer desires to communicate electronically. If the consumer does not, they can unsubscribe or opt out from continuing to receive messages through these channels.
Of the millions of email communications TrueAccord sends, only 0.10% of consumers unsubscribe, most using the unsubscribe link provided in the email. And out of the millions of text messages we send, all of which contain the phrase “Reply STOP to opt-out,” on average only 2.07% of consumers reply stop.
Additionally, email addresses offer a distinct advantage over physical addresses or phone numbers in that they remain consistent over time, while other contact details may change more frequently. For consumers who move often, such as military families, email ensures that they don’t miss important communications because of an outdated address or phone number. By allowing digital communication, New York can help ensure that important debt-related messages are delivered without the risk of missed communication due to address changes.
A balanced approach could allow debt collectors to reach consumers via email and SMS in a regulated manner, ensuring that consumers are protected from excessive or intrusive contact, while still enabling them to resolve their debts on their own terms.
You’ve seen the headlines—the federal government last week resumed collecting defaulted student loan payments from millions of people for the first time since the start of the pandemic. And how—debt collection will be through a Treasury Department program that withholds payments through tax refunds, wages and government benefits. This will undoubtedly have negative effects on credit scores and the resulting loss of access to funding going forward for many Americans.
How did we get to this point where so many people with student loans are unable to make payments on them? Taking a look back at the financial activity of those who deferred student loan payments in the first place gives us a good jumping off point, and combined with the challenging economic landscape over the past several years we can begin to understand the precarious financial situation unfolding.
Student Loan Holders Took on More Debt During the Pandemic
Based on data analysis we reported on in “Consumer Finances, Student Loans and Debt Repayment in 2023”, the trend for student loan holders who deferred their payments from 2020-2022 was to take on more debt. Data showed that the total average debt of a consumer with student loans increased 14.6% from 2020 to 2022, while that of consumers without student loans decreased 4.8%.
In 2022, student loan holders increased their average number of open trade lines by 10.3% from 2020, while open trade lines decreased by 7.7% for non-student loan holders. Breaking it down, those with student loans added credit cards (up 8%), personal loans (up 4%) and personal installment loans (up 5%) to their debt balances, with the average total balance of other loans more than doubling from 2020-2022, from $2,078 to $4,747, a 128% increase.
Economic Stressors Have Persisted, Are Likely to Continue
While inflation has cooled significantly compared to the highs of 2021 and 2022, prices remain elevated and interest rates haven’t returned to pre-pandemic levels. Uncoincidentally, household debt and credit card balances have been on a steady upward climb for the past few years, suggesting that rather than catching up with their finances, many Americans have continued to find new sources of funds to support their lives.
Americans’ total credit card balance was $1.2 trillion as of Q4 2024, marking the 10th time in 11 quarters where credit card debt increased or stayed the same. In a bigger picture view, credit card balances have risen by $441 billion since Q1 2021—adding up to a 57% increase in less than four years. Given the still-high interest rates, stubborn inflation (that may or may not go back up due to tariffs) and other turbulent economic factors, these balances are likely to keep climbing.
A Perfect Storm of Financial Challenges for Student Loan Holders
While deferred payments on student loans granted a temporary reprieve for borrowers, the new debt accrued effectively negated the gains of deferral, leaving many student loan holders with monthly debt obligations that were only manageable without having to pay back student loans. The CFPB reported that as of September 2022, 46% of student loan borrowers had scheduled monthly payments for all credit products (excluding student loans and mortgages) that increased 10% or more relative to the start of the pandemic.
Monthly financial obligations directly impact a consumer’s overall financial flexibility, and maxing out budgets to keep up with the economy puts people in a precarious situation when demands on finances change. That’s what we’re seeing now—consumers put student loans on the backburner and weren’t able to financially prepare for when they would come due again.
What Happens Next?
The outlook isn’t great: financially at-risk consumers with student loans will either go into collections for their student loans or will start missing payments on other loans in an attempt to pay back student loan debt. When there is only so much in the bank to work with and the cost of accessing new money is high, consumers will have to prioritize financial obligations and inevitably won’t be able to cover them all.
As we’ve learned from working with more than 40 million consumers in debt, empathy goes a long way, and understanding your customers’ financial situation is the first step to effectively engaging them in debt collection. For creditors and debt collectors looking to engage consumers in debt collection right now, it’s important to have a comprehensive, omnichannel communication strategy and be ready to meet the customer when and where they are ready to prioritize your account. This means don’t limit communication channels and do offer flexible options for repayment that consumers can explore, evaluate and select on their own time.
To engage your customers earlier in delinquency before charge off, consider leveraging consumer-preferred digital channels and AI-enabled decisioning for optimal results. Implementing a SaaS tool to automate digital communications will help you keep up with rising delinquencies while keeping your costs low.
What do canceled hair appointments and increased lipstick and beer sales have in common? These untraditional indicators, among other discretionary expenditure trends, often show consumer sentiments around finances well before a recession hits. Coming out of 2024, the average U.S. household owed $11,303 on credit cards, and while credit card charge-off rates and delinquencies both declined slightly, experts are not declaring a definitive turnaround given the ongoing economic uncertainties and high balances. Consumers today are confronted with new developments regularly, leading to “considerable turbulence” in the words of JPMorgan Chase CEO Jamie Dimon, and without much guidance on what the implications are for their personal financial outlook, which understandably affects their spending and budget considerations.
The main challenge in engaging with consumers in debt in today’s economic climate is how to offer them an affordable way forward. Other challenges for businesses’ debt collection operations come in the forms of regulatory changes impacting innovation and uncertainty about staying in compliance.
As you try to keep up with your bottom line in a rapidly evolving consumer financial landscape, let’s look at what you should consider as it relates to debt collection moving forward in 2025.
What’s Impacting Consumers?
It’s important to note that this report is from data covering a period of time before the majority of new tariffs went into effect, and everyone from Wall Street to consumers are waiting to see what happens next. Against a backdrop of an erratic market and general unease about the future of the U.S. economy, inflation reports offered a bright spot showing cooling in March to close out Q1. The consumer price index (CPI), excluding volatile food and energy costs, increased 0.1% from February, climbing 2.4% from a year earlier—the least in nine months and lower than expected. The overall CPI declined 0.1% from a month earlier, the first decrease in nearly five years, reflecting a decline in energy costs, used vehicles, hotel visits, car insurance and airfares.
The overall jobs numbers from March signaled a solid labor market, with employers adding 228,000 jobs and the unemployment rate changing little to 4.2%. Job gains showed up
in health care, social assistance, transportation and warehousing, along with retail trade, which reflected the return of workers from a strike, while federal government employment declined as a result of wide-reaching layoffs.
The Federal Reserve (Fed) held rates steady at 4.25-4.50% in March. In its statement following the March meeting, the Fed stated that “uncertainty around the economic outlook has increased.” As a result, the Fed lowered economic growth expectations to 1.7% gross domestic product (GDP) growth in 2025, down from a 2.1% estimate, while upping the projected core PCE inflation rate to 2.8% from 2.5%. The next meeting is on May 6 and while many still expect two rate cuts this year, the outcome will reflect the bank’s outlook given the new landscape of tariffs and their anticipated impact on inflation.
In February, the Fed released its Quarterly Report on Household Debt and Credit for Q4 2024, which showed total household debt increased by $93 billion in Q4, to $18.04 trillion. The report also showed that people are having more trouble paying off that debt, with credit card balances increasing by $45 billion to $1.21 trillion and auto loan balances increased by $11 billion to $1.66 trillion. Delinquency rates ticked up 0.1% from the previous quarter, with 3.6% of outstanding debt now in some stage of delinquency. Transition into serious delinquency, or 90+ days past due (DPD), also increased for auto loans, credit cards and HELOC balances.
Experian’s Ascend Market Insights from February 2025 data showed that overall delinquent balances (30+ DPD) increased by 16.67%, driven by a 537.4% increase in delinquent student loan balances, a 16.28% increase for first mortgages and a 4% increase for bankcard balances. The huge surge in delinquent student loans is due to an increase in the volume of 90 DPD data furnishers have started to report after the pause on student loan payments ended.
By the end of February, nearly 8 million people with student loans had missed resumed payments and were met with plunging credit scores. As it stands, 1 in 5 people who are supposed to be making payments on their federal student loans are more than 90 DPD, nearly double the percentage of delinquent borrowers since the pandemic hit and the government paused payments, with reasons for delinquency ranging from inability to pay and difficulties working with servicers to missed communications that never reached the recipient.
The CFPB, Regulations and Compliance are Evolving
While the Consumer Financial Protection Bureau’s (CFPB) normal activity has been disrupted due to changes in direction from the administration, it did release a report looking at national rental payment data from September 2021 to November 2024 showing that the percentage of renters who paid late fees in the last year reached 23% in February 2023. While the rate had declined to slightly less than 14% in November 2024, the CFPB’s analysis found that the median outstanding rental balance rose 60% between September 2021 and November 2024, suggesting increased financial distress among affected households.
Meanwhile, the Federal Communications Commission (FCC) is seeking public input on identifying FCC rules for the purpose of alleviating unnecessary regulatory burdens. In a public notice released March 12, 2025, the FCC announced the Commission is seeking comments on deregulatory initiatives to identify and eliminate those that are unnecessary in light of current circumstances. The FCC notice stated: “in addition to imposing unnecessary burdens, unnecessary rules may stand in the way of deployment, expansion, competition, and technological innovation.”
In the meantime, two FCC Orders about the Telephone Consumer Protection Act (TCPA), which applies only to calls and texts made by an automated telephone dialing system (ATDS) and prerecorded or automated voice calls (aka robocalls or robotexts) come into effect. First, a 2024 Order released last February impacting revocation of consent to receive autodialed calls and texts and prerecorded or artificial voice calls. The 2024 Order conflicts with the CFPB’s Regulation F Debt Collection Rule about the scope of an opt-out. Second, is a 2025 Order released this past February aiming to strengthen call blocking of illegal calls, which may result in the blocking of lawful debt collection calls and texts.
Debt collectors and other companies impacted by these two orders may want to submit comments to the FCC identifying the particularly burdensome aspects that could be revisited and slightly revised to be consistent with consumer preference, consistent with other laws and regulations (like Regulation F), and less burdensome on companies.
Eyes will continue to be on the developments with the ever-evolving regulatory landscape and what happens with the CFPB, which will impact how businesses both comply with regulations and innovate through technology in consumer financial services.
Consumer Sentiment
The Fed’s March Survey of Consumer Expectations showed that inflation expectations increased by 0.5% to 3.6% at the one-year-ahead horizon while consumers’ expectations about their households’ financial situations deteriorated with the share of households expecting a worse financial situation one year from now rising to 30%, the highest level since October 2023. The report also showed Unemployment, job loss, earnings growth and household income growth expectations also deteriorated.
The latest University of Michigan consumer sentiment survey showed that sentiment fell to 50.8, down from 57.0 in March. The drop, a 10.9% monthly change and 34.2% lower than a year ago, was the lowest reading since June 2022 and the second lowest in the survey’s history since 1952. Respondents’ expectation for inflation a year from now jumped to 6.7%, the highest level since 1981. The current economic conditions index and expectations measure dropped by 11.4% and 10.3% from March respectively.
Similarly, the Conference Board’s Consumer Confidence Index in March fell by 7.2 points to 92.9. The Present Situation Index, based on consumers’ assessment of current business and labor market conditions, also decreased 3.6 points to 134.5 while the Expectations Index based on consumers’ short-term outlook for income, business and labor market conditions fell 9.6 points to 65.2, the lowest level in 12 years and well below the threshold of 80 that usually signals a recession ahead.
What Does This Mean for Debt Collection?
All of the economic indicators and pessimistic consumer outlook, especially given stock market turbulence that impacts many Americans’ retirement savings, makes it likely that consumers across all income brackets will pull back on discretionary spending. And for those already financially stressed, the added burden of increased inflation due to tariffs could make it harder for budgets to meet debt obligations. For lenders and collectors, here are some recommendations for your debt collection strategy in 2025:
Ensure Your Messages Are Getting Through. If you’re calling someone who prefers to receive information by email, they likely won’t answer and get your message. Similarly, if you’re using digital channels and your email gets caught in a spam folder, your message won’t make it to the intended recipient. Best practices for email delivery and deliverability are just as important as using the right channel. Ensure your collection partners who claim to engage consumers via email can back it up with the metrics to prove that their messages actually make it through.
Do More With Less. Technology exists today that can create efficiencies across many aspects of debt collection operations, which means increasing account volume doesn’t have to equal higher costs. Look for ways you and your collection partners can leverage new tech to streamline operations and you can reap the benefits of improved operational efficiency, compliance efforts and consumer experience.
Get Your Lawyer on Speed Dial. Or ensure your debt collection partner is keeping tabs on the rapidly evolving regulatory and compliance landscape to inform their practices. There’s a lot going on, quickly, and if you miss something the repercussions of noncompliance could cost you financially or reputationally.
Efficiency, accuracy, and compliance are critical in the fast-paced world of debt collection. TrueAccord, a leader in digital-first debt collection, is leveraging Robotic Process Automation (RPA) bots to transform the industry and improve operational efficiency, compliance efforts, and customer experience.
At TrueAccord, we’re not just collecting debt; we’re revolutionizing the process with this kind of cutting-edge technology. These aren’t your average macros; they’re sophisticated software tools that automate repetitive tasks, freeing up our team to focus on more complex and strategic work. In this blog post, we’ll explore how TrueAccord is utilizing RPA technology, our unique approach to automation, and the benefits that this technology offers to our company and our clients.
What is an RPA Bot?
RPA bots are software tools designed to automate repetitive, rule-based tasks traditionally performed by humans. These bots interact with digital systems in the same way a human would—by clicking buttons, entering data, or reading information from documents. They can handle tasks like customer service inquiries, data entry, invoice processing, and report generation, improving efficiency and accuracy while reducing human error. RPA bots can even be strategically utilized to enhance first line controls and compliance monitoring, which are vital processes for debt collectors. RPA bots can be programmed to work across various applications and systems without needing complex integrations, making them a versatile solution for automating business operations.
RPA is particularly valuable for organizations looking to improve productivity and reduce costs. By automating repetitive and time-consuming tasks, employees can focus on higher-value activities that require a nuanced approach or complex problem-solving. RPA bots can be set up quickly and are scalable, making them ideal for businesses of all sizes. As they operate 24/7 without the need for breaks or downtime, they can significantly enhance operational efficiency while ensuring consistency and speed in completing tasks.
For example, when issues arise, there might be a need to update thousands of accounts. Previously, a human would have to manually go into each account, add a comment, and make necessary updates. With RPA, bots take care of this task in a fraction of the time, updating entire lists of accounts in minutes instead of hours or even days.
How does TrueAccord Use RPA Bots?
At TrueAccord, RPA is a key part of how we ensure compliance, respect consumer preferences, and drive better outcomes across the debt collection lifecycle. By automating previously manual tasks, RPA bots help us maintain accuracy, consistency, and adherence to regulatory requirements. Many of our bots operate through API (Application Programming Interface) calls, which connect directly to backend systems—making the processes faster, more reliable, and less prone to human error than traditional UI-based automation.
What makes RPA even more powerful at TrueAccord is its ability to run continuously, 24/7. Unlike human workers, bots don’t need breaks (both from a stamina aspect and a HR/legal aspect), and they can work around the clock, completing tasks whenever necessary. This constant availability, paired with their ability to handle large volumes of work, turns RPA into a digital workforce capable of handling countless processes simultaneously. For instance, TrueAccord runs 45 different processes through RPA, including posting over 60,000 direct-to-creditor payments each month on behalf of just one client. This would have normally required an army of humans, but with RPA, the task is completed efficiently and accurately without mistakes like “fat-fingering” data.
Enhancing Compliance and Customer Experience
Compliance is a significant focus in the debt collection industry, and TrueAccord takes it seriously. The use of RPA bots helps ensure that processes are executed consistently and in line with legal and regulatory requirements. For example, when a consumer requests to opt-out of a communication channel such as email or text message, the bots automatically process this request, ensuring that the consumer’s preferences are respected in real time. This helps TrueAccord remain compliant with regulations and provides a better experience for the consumer, as they don’t have to wait for a human to process their request.
Beyond compliance, RPA is also improving the consumer experience. For example, when consumers respond to a text message or email communications, RPA bots can automatically pause the account, allowing time for review and ensuring that the consumer’s issue is addressed promptly.
The Future of RPA at TrueAccord
TrueAccord is not stopping at just using RPA for backend processes; we’re exploring new frontiers by combining RPA with Artificial Intelligence (AI). By integrating AI with RPA, TrueAccord aims to create an intelligent, self-sufficient digital workforce. AI acts as the “brain,” interpreting consumer requests and generating responses, while RPA serves as the “muscle,” executing tasks like updating accounts, posting notes, and more.
This combination of AI and RPA has already shown significant results, such as faster response times and better consumer satisfaction. For example, where human agents might take days to respond to emails, AI-powered bots can provide answers in under 90 seconds, ensuring that consumers get quick and accurate responses. Over time, these innovations will continue to evolve, enabling even more intelligent and responsive automation.
TrueAccord’s RPA program is a testament to our commitment to innovation and efficiency. By developing our bots in-house with team members who understand our processes, we’ve created a robust and tailored system that truly makes a difference. We’re not just keeping up with the industry—we’re leading it.
APRIL 15 UPDATE: FCC GRANTS ACA’S PETITION TO EXTEND EFFECTIVE DATE
On April 7, 2025, the Federal Communications Commission FCC issued an order granting a limited waiver that extends the effective date —for a full year—to April 11, 2026 of the revocation provisions from the February 2024 Order. The specific rule section that is being delayed is 47 CFR § 64.1200(a)(10) of the Commission’s Order requiring businesses to treat a consumer’s reasonable revocation to revoke consent as revocation for all future calls and texts to that phone number. That specific section reads in part:
“A called party may revoke prior express consent, including prior express written consent, to receive calls or text messages made [using an autodialer as defined by the TCPA, using a prerecorded voice, or to a subscriber on the do not call registry] by using any reasonable method to clearly express a desire not to receive further calls or text messagesfrom the caller or sender.”
No other rules adopted in the February 2024 Order are changed by the delay. The FCC decided to make these changes after receiving a request to delay the effective date from ACA International and several other associations (ABA, AFSA, Mortgage Bankers), explaining the implementation complications for both larger institutions having multiple business units and systems and smaller institutions having more manual processes and third party vendors to coordinate. The FCC rules allow for the Commission to consider and order such changes upon special circumstances that warrant a deviation, like undue hardship, equity, or more effective implementation of overall policy. The Commission found good cause to push back the effective date due to the challenges all businesses face in processing revocation requests across multiple business units, systems, and vendors.
The extension gives businesses more time to do two things: (1) implement changes across systems, units, and vendors to operationalize the rule and (2) file a comment identifying the same provision as an unduly burdensome rule by the April 28, 2025 comment deadline for the Commission’s deregulatory initiative.
The blog post below was originally published on March 26, 2025 and has been updated to address the changes based on the new April 7, 2025 Order.
The Federal Communications Commission (FCC) is seeking public input on identifying FCC rules for the purpose of alleviating unnecessary regulatory burdens. In a public notice released March 12, 2025, the FCC announced the Commission is seeking comments on deregulatory initiatives to identify and eliminate those that are unnecessary in light of current circumstances. The FCC notice stated: “in addition to imposing unnecessary burdens, unnecessary rules may stand in the way of deployment, expansion, competition, and technological innovation.” Reply comments are due by April 28, 2025.
In the meantime, two FCC Orders that both impact the debt collection industry come into effect:
A 2024 Order released last February impacting revocation of consent to receive autodialed calls and texts and prerecorded or artificial voice calls. The 2024 Order conflicts with the CFPB’s Regulation F Debt Collection Rule about the scope of an opt-out.
And a 2025 Order released this past February aiming to strengthen call blocking of illegal calls. The 2025 Order may result in the blocking of lawful debt collection calls and texts.
Debt collectors and other companies impacted by these two orders may want to submit comments to the FCC identifying the particularly burdensome aspects that could be revisited and slightly revised to be consistent with consumer preference, consistent with other laws and regulations (like Regulation F), and less burdensome on companies.
Quick Note: These FCC rules are about the Telephone Consumer Protection Act (TCPA), which applies only to calls and texts made by an automated telephone dialing system (ATDS) and prerecorded or automated voice calls (aka robocalls or robotexts).1 If you do not use an ATDS to make calls or texts, and you don’t use prerecorded or automated voice calls, these Orders do not apply to your communications.
I. 2024 Order – Special Revocation Rules
On February 15, 2024, the FCC published an order adopting rules which impact text messaging and outbound dialing using an ATDS as well as calls made with prerecorded or automated voice. Most provisions of the Order take effect April 11, 2026.2 Those provisions include:
Consumers can revoke consent by “any reasonable manner”
If consent is revoked it applies to both “robo texts” and “robo calls”
Companies must process do-not-call and consent revocations requests within a reasonable period of time not to exceed 10 business days of receipt.
Originally these provisions were to take effect on April 11, 2025; however, in response to a petition from ACA International and other trade associations, the FCC on April 7, 2025 issued an order granting a limited waiver that gives companies an additional year to operationalize the revocation rules, changing the effective date to April 11, 2026. The Order also limited senders of text messages made using an ATDS to a one-time, revocation-confirmation text. This provision took effect in April of 2024.
a. Revoking consent is super flexible.
The FCC Order establishes that consumers may revoke prior express consent for autodialed or prerecorded/artificial voice calls and texts in any reasonable manner. This means that companies cannot designate an exclusive means to revoke consent that precludes the use of any other reasonable method.
A non-exhaustive list of “reasonable” ways a consumer can revoke consent include:
Request made using an automated, interactive voice, or key press-activated opt-out mechanism on a robocall
A response of “stop,” “quit,” “end,” “revoke,” “opt out,” “cancel,” or “unsubscribe,” or a similar, standard response message sent in reply to an incoming text message
Request submitted at a website or telephone number provided to process opt-out requests
If a sender uses a texting platform that does not allow two-way texting, the sender must clearly and conspicuously disclose in each text that (1) replying is unavailable and (2) provide the details of other reasonable alternative ways the consumer can revoke consent.
If a consumer uses any reasonable method to revoke consent, the FCC considers that consent to be definitively revoked, and future robocalls and texts from that company must be stopped.
Note that effective as of this April 11, 2025, a company must honor other revocation methods than key word replies to the text message. A consumer’s use of any other method to revoke consent, such as a voicemail to the sender’s telephone number or email address, creates a rebuttable presumption that consent has been revoked. If there is ever a dispute about whether a consumer reasonably revoked consent, the sender has the burden to show why they did not treat the consumer’s communication as a revocation.
b. Revocation applies to the number, not the channel.
The Order states that when consent for autodialed calls or texts is revoked, that revocation extends to both robocalls and robotexts regardless of the channel used to communicate the revocation. It is the FCC’s position that a consumer grants consent to be contacted at a particular wireless phone number or residential line, and therefore, consent revocation is an instruction to no longer contact the consumer at that number.
This FCC interpretation is different from the CFPB’s approach in Regulation F, which prevents debt collectors from contacting a consumer in a channel after the consumer opts out of communications in that channel. Under Regulation F, if a consumer opts-out from texts it does not require opting the consumer out of calls to that number. This FCC Order has a broader effect—if a consumer revokes consent to text by text, it requires opting the consumer out of all communications to that phone number (calls and texts).
c. Ten business days to process revocation.
The FCC now requires that companies honor opt-out/revocation requests within a reasonable period of time, not to exceed 10 business days of receipt. The FCC chose 10 business days since it was consistent with the timeframe to process revocation requests under the CAN-SPAM rules. However, the FCC made clear that it will continue to monitor advances in technology to see if faster processing times may be warranted in the future, and it explicitly stated “[w]e encourage callers to honor such requests as soon as practicable as a best practice.”
This particular provision is also at odds with the FDCPA, as the FDCPA does not contain language offering a reasonable processing time for opt-outs or any inbound requests (like cease and desist, notice of attorney representation, etc.). The CFPB did not provide any reasonable processing time for opt-outs in Regulation F.
II. 2025 Order – Enhanced Call Blocking Rules
On February 27, 2025, the FCC published an order seeking to strengthen the call blocking and robocall mitigation rules requiring all providers in the chain to block calls that are highly likely to be illegal based on a reasonable Do Not Originate (DNO) list. In the past, lawful debt collection calls have unfairly been blocked in these efforts. This Order has different effective dates but the earliest is May 2025.
a. Every provider must block illegal calls.
The FCC Order requires all providers in the call path to block calls that are “highly likely to be illegal” based on a reasonable DNO list. With this Order the FCC expands the requirement from prior Orders, now requiring all providers to block suspected illegal calls.
FCC does not mandate a particular list for providers to use. This is because providers know their own networks and may be better positioned to determine what types of numbers should be prioritized. As long as the provider can show that the list is reasonable, the provider will be in compliance with the Order. Providers must constantly update the lists and will want to show that their list is comprehensive to safeguard consumers.
This provision of the Order goes into effect 90 days after the order is published in the Federal Register. This order has not been published in the Federal Register as of the date of this blog post, but we should prepare for this rule to go into effect as early May 2025.
b. Special code for immediate notification of blocking to a caller.
The FCC has designed SIP Code 603+3 as the return call the provider must immediately use to notify callers when their calls are blocked based on “reasonable analytics.” This is the exclusive code for this purpose on IP networks. Using this code will ensure that callers learn when and why their calls are blocked based on reasonable analytics, which will allow these callers to access redress when blocking errors occur. This stems directly from the TRACED Act that requires the Commission to ensure that callers receive “transparency and effective redress” when their calls are blocked by analytics, and a single uniform code is the best way to achieve this transparency.
This requirement only applies when the call is based on analytics. If a call is blocked based on a DNO list, there is no requirement to provide immediate notification.
The Order further directs voice service providers to cease using the standard version of SIP code 603, or SIP codes 607 or 608, for this purpose.
The Order does not provide any additional protections for lawful callers because the FCC does not adopt any requirements for blocking based on reasonable analytics and the blocking notification rules adopted in the Order are expansions of our existing rules, rather than wholly new requirements. The Order states:
The record does not suggest that our current protections will be insufficient to protect lawful callers after these particular incremental expansions take effect. Moreover, and as discussed previously, we believe that the deployment of SIP code 603+ will provide significant benefit to callers that, when paired with our existing protections, are sufficient to protect the interests of callers.
This provision of the Order goes into effect 12 months (one year) after the order is published in the Federal Register. This order has not been published in the Federal Register yet, but it could go into effect as early March 2026.
c. No requirement to display caller name (yet).
The FCC declined to require the display of caller name information when a provider chooses to display an indication that caller ID has been authenticated. Although it does not adopt such a mandate, the FCC urges providers to continue to develop next-generation tools, such as Rich Call Data (RCD) and branded calling solutions, to ensure that consumers receive this information and welcome any updates industry has on its progress. The FCC noted that it may consider a mandate in the future, particularly if the timely deployment of such valuable tools does not occur without Commission intervention.
*This blog is not legal advice. Legal advice must be tailored to the particular facts and circumstances of each unique matter.
Citations:
An ATDS or autodialer under the TCPA is a system that has the capacity to use a random or sequential number generator to either store or produce phone numbers to be called. To learn more about this read this blog.
The Order also limited senders of text messages made using an ATDS to a one-time, revocation-confirmation text. This provision took effect in April of 2024.
A SIP (Session Initiation Protocol) code, also known as a SIP response code, is a three-digit numerical code used to indicate the status of a SIP request or transaction, similar to HTTP status codes.
In today’s world, connecting with consumers requires more than just making a phone call or sending a standard email, especially in the realm of debt recovery and collection. Navigating through the various strategies often feels like wading through a sea of acronyms and buzzwords. Terms like AI, machine learning, and data science can quickly become overwhelming or even feel interchangeable, leaving you unsure of what they actually mean and how they affect your business and bottom line.
To help clear up the confusion, we’ve put together a glossary of key terms, definitions, and examples to help you make sense of it all:
Artificial Intelligence (AI): AI is a broad field, which refers to the use of technologies to build machines and computers that have the ability to mimic cognitive functions associated with human intelligence.
Big Data: This term means larger, more complex data sets. Big data can save collectors a lot of time by using many variables for analytics-based customer segmentation, insert, insert.
Champion/Challenger: This model of A/B testing is a method for comparing the performance of a current strategy, agency, or software (the champion) to an alternative solution in the same category (the challenger), often used in debt collection to evaluate two agencies or service providers.
Dark Patterns: A dark pattern (also known as a “deceptive design pattern”) is a user interface or flow that has been crafted to trick users into doing things. Although dark patterns are often considered to be intentionally deceptive, poor design can inadvertently result in an unintended dark pattern.
Data Science: A cross-discipline combination of computer science, statistics, modeling, and AI that focuses on utilizing as much as it can from data-rich environments. Data science (which includes machine learning and AI) requires massive amounts of data from various sources (customer features such as debt information or engagement activity) in order to build the models to make intelligent business decisions.
Data Mining: Data mining describes the process whereby you dig through data to discover hidden connections and patterns, and then use this data to predict future trends. Most often it uses a combination of machine learning and artificial intelligence and is very much related to Big Data.
Digital Opt-In: The percentage of users who have indicated their preference to receive digital communications in a particular channel.
Digital Opt-Out: Percentage of users who have requested to be removed from a specific communication channel or all lists owned by the sender. Opt-out requests can be relayed through a variety of words or phrases beyond the standard “STOP.”
Domain Reputation: Domain reputation is the opinion receivers—including mailbox providers, ESPs, and other service providers—have of your domain, which helps them decide if your emails should make it to a recipient’s inbox instead of being rejected or ending up in a spam folder. Domain reputation is a key factor for email deliverability rates.
Email Deliverability Rate: Deliverability, or inboxing rate, divides how many emails reach the recipient’s inbox, as opposed to their spam folder, by the total number of emails sent. Your deliverability is influenced by a variety of fluctuating factors, including Internet Service Providers (ISPs).
Email Delivery Rate: Email Delivery Rate refers to the successful transmission of an email from the sender to the recipient’s mail server. It is the measurement of emails delivered divided by the number of emails sent. Bounces (when an email gets rejected by the mail server for any reason) and failures will impact this number.
ESPs: Email service providers (ESPs) are a service that enables businesses to send emails and email campaigns to a list of subscribers.
Generative AI: AI that creates new content. (Images, Text, Sound, etc.)
ISPs: Internet Service Providers (ISPs) provide internet. Although ISPs can provide email services, separate ESPs are often used for business email operations—but ISPs play a major role in email delivery and landing in the recipient’s inbox.
Mailbox Provider: A mailbox provider provides email hosting and implements email servers to send, receive, accept, and store email for the recipient.
Mail Server: A mail server (also known as a mail transfer agent or MTA) is an application that receives incoming email from the sender and forwards outgoing messages for delivery to the recipient.
MMS: An acronym that stands for Multimedia Messaging Service, similar to SMS, that allows for multimedia content like images, videos, and audio, along with longer text messages.
Multi-channel: Multi-channel communication refers to the use of multiple, separate communication channels to reach a consumer—such as email, text messages, phone calls, letters, or even self-service portals—but each channel operates independently from the others, and there is little to no integration between them.
Open Rate, Click-Through Rate: The percentage of users who are actually opening and clicking digital communications.
Predictive Analytics: Predicting outcomes is one specific application of machine learning. It allows companies to predict which accounts are more likely to pay sooner and allows them to better plan operations accordingly.
SaaS: Software as a Service (SaaS) is a cloud based technology that uses the internet to deliver an application which is owned, managed and developed by an external party. Normally run on a subscription basis, the software is usually not installed on the user’s device.
Scalability: In debt collection, scalability is the ability to handle more debt and customers while maintaining efficiency and cost-effectiveness of the operation, often involving or determined by the utilization of employees or third-party agencies, the application of different software, optimizing processes, and adopting new technologies.
Self-Serve: A self-service or self-serve portal is a secure online platform or application designed to empower consumers to make payments and, ideally, allow them to manage their accounts and payment terms independently.
Tech Debt: Often tech debt refers to the unnecessary reworking or refactoring of code, design, or implementation due to prioritizing speed over quality of work.
TrueAccord is a machine-learning and Al-driven 3rd-party debt collection company that is reinventing debt collection. We make debt collection empathetic and customer-focused and deliver a great user experience.
Our digital-first approach to debt collection creates a cycle of collections growth:
1. Improve the perception of the industry
2. Provide a personalized experience
3. Build brand equity and collect
