Although debt collectors had a full year and more than 1000 pages of CFPB guidance to assist in preparing for Regulation F, some facets of this new law remain murky. Many debt collectors are unclear if the Zortman phone message may still be used after implementation of Regulation F or does the limited content message (LCM) replace it? Further, questions arise daily about the permissible extent of modifications to the model validation notice (MVN), especially when collecting on multiple debts for the same obligor.
In the latest episode of the Debt Collection Drill videocast, Moss & Barnett attorneys John Rossman and Mike Poncin break down the differences between the Zortman message and the LCM, including acceptable uses. In addition, the attorneys examine the allowed scope of potential modifications to the MVN, specifically focusing on the inclusion of debits in the itemization and placement of a payment portal web address on the notice.