June 16, 2026 7 min read

The Collection Compliance Checklist for 2026

A practical, agency-side compliance checklist covering licensing, call cadence, disclosures, disputes, and state overlays — before your next campaign goes live.

Before a new campaign, portfolio, or state goes live, run it against this checklist. It won't replace your legal counsel's sign-off, but it will catch the mistakes that show up most often in real operations.

1. Licensing & bonding

  • Is the agency licensed in every state where consumers reside?
  • Does the state require a surety bond (e.g., Texas), and is it filed and current?
  • Are individual collectors licensed where required?

2. Call cadence & timing

  • Is the dialer enforcing the 7-in-7 rule per debt, not per account?
  • Are calling windows calculated by the consumer's time zone, not the agent's — including DST changes twice a year?
  • Is there a workplace-contact flag once you learn the employer prohibits it?

3. Disclosures & validation

  • Is the mini-Miranda disclosure delivered verbatim on every call?
  • Does the validation notice go out within 5 days of initial communication, using the model-notice safe harbor language?
  • Is the itemization date one of the five permitted reference points under Regulation F?

4. Disputes & hard stops

  • Is collection paused immediately on a written or oral dispute of any portion of the debt?
  • Are attorney-representation, bankruptcy, cease-and-desist, and identity-theft statements routed to an immediate stop-and-escalate flow — not a scripted rebuttal?
  • Is every dispute logged with a timestamp and outcome?

5. State overlays

  • For California accounts, is the Rosenthal Act applied alongside the FDCPA?
  • For New York accounts, are the state/NYC disclosure-timing and language-access rules met?
  • Has each state's licensing and calling-hour rules been confirmed — not assumed from the federal baseline?

6. Payment & settlement handling

  • Is every electronic payment authorization captured for a specific amount and date, on a recorded line?
  • Are settlements confirmed in writing before being treated as final?
  • Does the agent state the 1099-C fact (never tax advice) when forgiveness comes up?

Run this checklist per campaign, not just once a year — rules change, and Regulation X's proposed 2024 overhaul is a live example of a framework still moving through rulemaking as of 2026. Treat monitoring, not memory, as your compliance system.

Put this into practice

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