> For the complete documentation index, see [llms.txt](https://docs.moderncollections.io/llms.txt). Markdown versions of documentation pages are available by appending `.md` to page URLs; this page is available as [Markdown](https://docs.moderncollections.io/compliance-for-integrators/fdcpa-for-integrators.md). # FDCPA for integrators > **Not legal advice.** Get your own counsel. ## What FDCPA is The Fair Debt Collection Practices Act (15 U.S.C. § 1692). Federal law restricting how third-party debt collectors can pursue **consumer debts** in the United States. Key points: * Applies to "consumer debt" (personal, family, household purposes). * Restricts time, place, manner, and content of communications. * Requires validation notice within 5 days of first communication. * Pauses collection on a written dispute until validation is provided. * Restricts third-party disclosure (you can't tell the debtor's neighbor about the debt). ## Does FDCPA apply to B2B debt? **Usually no.** B2B debt is generally outside FDCPA's "consumer debt" scope. **But:** * **Sole proprietors:** A sole-proprietor debt is often treated as a *personal* debt. FDCPA applies. * **Personal guarantees:** If the debt is personally guaranteed by an individual (common in small-business SaaS contracts), the personal-guarantee side may be FDCPA-covered. * **State analogues:** Many states have B2B versions of FDCPA-style restrictions (e.g. New York's Article 29-H). * **Some courts**: have stretched FDCPA into mixed-use debts (a self-employed contractor's business expense, etc.). Our platform applies FDCPA-compliant defaults — quiet hours, mini-Miranda, recording disclosure — driven by a versioned per-state rules matrix and the compliance engine. The debtor's `entity_type` is captured on every record (`unknown` by default); when a sole-prop or personally-guaranteed signal is present the engine treats the debt with the more conservative posture. ## What integrators need to do ### On placements you file * The `PlacementCreateRequest` schema does NOT accept an `entity_type` or a freeform `metadata` field today. Use `notes` to flag personally-guaranteed debt so the operator triage queue surfaces it. * Set `debtor.state` accurately — it drives quiet-hours computation and the state-rules matrix the compliance engine evaluates against. * Don't withhold information that would flip our compliance evaluation. We need to know. ### On webhook payloads * Webhook payloads may contain content that, if mishandled, could create FDCPA-style exposure for the creditor (e.g. forwarding a transcript to someone who's not authorized to see debt info). * Keep debt-info access on your side **on-need-to-know**. * Don't expose webhook payloads to channels with unverified audience (e.g. don't pipe webhooks to a public Slack workspace). ### On debtor-initiated dispute and cease requests * If a debtor disputes the debt via YOUR channels (email to your AR team, etc.), forward to us promptly — ideally within 24 hours. Today there is no creditor-facing `POST /v1/disputes` endpoint; route the debtor to the portal or contact support to open the dispute on their behalf, then use `POST /v1/placements/{id}/dispute/acknowledge` once the row exists. * Same for cease-contact requests. The voice agent captures cease signals automatically via the `capture_cease` hard-stop, but channel-side requests routed through you require manual forwarding. ### On validation notice * We send the FDCPA validation notice when we first communicate with the debtor on FDCPA-covered debts. * You should not separately attempt collection (via your own dunning emails or calls) on a placement we're working — the validation notice is OUR responsibility on the channels WE use, but parallel uncoordinated outreach from you could violate FDCPA. ## Common pitfalls | Pitfall | What goes wrong | | --------------------------------------------------------------------------- | ---------------------------------------------------------------------------------------------------------------------------------- | | Not flagging known sole-prop / personally-guaranteed debt (e.g. in `notes`) | We can't always detect sole-prop on our own (`entity_type` starts as `unknown`); the conservative posture isn't applied. Exposure. | | Continuing your own dunning on a placement we have | Double-contact is potentially FDCPA-violating | | Storing transcripts indefinitely without access controls | Transcripts include consumer-debt-related content; long-term unrestricted storage is risk | | Pushing webhook payloads into a CRM with broad team access | "Third-party disclosure" risk | ## See also * [TCPA for integrators](/compliance-for-integrators/tcpa-for-integrators.md) * [Recording consent](/compliance-for-integrators/recording-consent.md) * [Data handling and PII](/compliance-for-integrators/data-handling-pii.md) --- # Agent Instructions This documentation is published with GitBook. GitBook is the documentation platform designed so that both humans and AI agents can read, navigate, and reason over technical content effectively. 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