> 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/recording-consent.md).

# Recording consent

> **Not legal advice.** Get your own counsel.

## The framework

State call-recording laws split into two camps:

* **One-party consent (majority of states):** at least one party to the call must consent. Since the agent is a party AND it consents to recording, the call can be recorded without explicit debtor consent.
* **Two-party (all-party) consent:** every party to the call must consent. Per the platform's state-rules matrix (v1.2.0), the platform treats the following 12 states as two-party: **CA, CT, DE, FL, IL, MD, MA, MT, NV, NH, PA, WA**. Note that Michigan is NOT on this list today — verify with counsel before relying on the encoded matrix for any state.

The voice agent renders a recording-disclosure prompt at the start of every call. The disclosure text is versioned (currently `v1`) and comes in two variants:

* **One-party states** — `"This call may be recorded for quality and compliance purposes."` (disclosure-only)
* **Two-party states** — `"This call may be recorded for quality and compliance purposes. Do you consent to the recording of this call?"` (solicits explicit consent)

The voice agent selects the variant based on the compliance engine's consent-before-record guardrail. Two-party states plus the mini-TCPA states (FL, OK, TX today) force consent collection.

## What this means for integrators

### Transcripts you receive

When you fetch a transcript via REST (`GET /v1/placements/{id}/calls` — webhook payloads carry a `summary`, not the transcript), you're receiving the **text representation** of a recorded call. The legal framework around the recording largely transfers to the transcript:

* If the call was lawfully recorded under one-party-consent rules, the transcript is generally OK to store.
* If the call was in a two-party state and we obtained valid consent, again generally OK.
* **You generally cannot turn around and re-distribute the transcript** to parties who didn't have access to the original call.

### Recording URLs

We provide pre-signed recording URLs with 1-hour expiry. If you choose to download and store the audio:

* Storage must be access-controlled.
* Retention should match your declared data retention policy.
* Some states limit how long recordings of consumer calls can be retained without consent renewal.

### Transcript streaming

Live transcript streaming is not available today. If it ships, a live stream will carry the same legal posture as the recording — derived from a consented-to call. If you build features that re-share transcripts (e.g. a "what did our agent say" view available to internal staff), keep audience access controlled.

## California SB 1286 / AB 1521

California's SB 1286 (the Fair Debt Buying Practices Act extension) adds disclosure and notice requirements for collections calls in CA. AB 1521 (effective January 1, 2026) excludes B2B trade credit (open-account invoices for goods/services) from SB 1286 — our core B2B use case is largely carved out via `trade_credit_exempt_from_sb1286: true` in the CA state record.

The Rosenthal commercial threshold for non-trade-credit commercial debt remains `$500,000` per `rosenthal_commercial_threshold: 500000`. AB 2905's 10-second AI disclosure requirement still applies. All-party recording consent still applies. The compliance engine surfaces all three via `special_rules: ["ca_sb1286", "ca_ab2905"]`.

If you forward CA-debtor data to channels of your own, those channels may have their own SB 1286 / CCPA implications.

## What you should NOT do

* Forward call transcripts to debtor third parties.
* Embed full transcripts in unrestricted Slack channels.
* Publicly post transcripts in any form (e.g. case-study screenshots).
* Use transcripts for training your own ML models without analyzing the consent implications first.
* Retain audio recordings beyond what your retention policy specifies.

## What you CAN do (generally — verify with counsel)

* Read transcripts internally on a need-to-know basis (collections-team review).
* Use transcript content for legitimate compliance-investigation purposes.
* Cite specific lines from a transcript in correspondence directly with the debtor (e.g. dispute responses).
* Use anonymized excerpts (with debtor identifiers redacted) for internal training of your collections staff.

## Compliance flags from us

If during a call our agent detected an event that affects the recording's legal posture (debtor revoked consent mid-call, debtor was in a two-party state and the consent was ambiguous, etc.), the call record's `compliance_flags` will carry it. The `call.completed` **webhook** payload does not include `compliance_flags` — read them from `GET /v1/placements/{id}/calls` or the `call.completed` audit event. Investigate before re-distributing.

## See also

* [AI disclosure](/compliance-for-integrators/ai-disclosure.md)
* [Data handling and PII](/compliance-for-integrators/data-handling-pii.md)


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