14 Calls in 22 Days is Reasonable, Says Court

Collecting debt can sometimes feel like a delicate balancing act; debt collectors must navigate challenging situations with precision and care. Getting a consumer on the phone to discuss their account can be difficult, especially considering the concern of potential Fair Debt Collection Practices Act (FDCPA) violations for calling too often. While that is true to an extent, a recent North Carolina case highlights that reasonable calling is still permitted despite general inconvenience or annoyance to the consumer.

In Brayton v. Alltran Financial, LP, 21-309 (W.D. N.C. 2023), the consumer alleged that a debt collector violated the FDCPA by calling the consumer 14 times in 22 days. In response, the debt collector asked the court to issue a judgment in its favor because this call volume is reasonable and did not violate the FDCPA. 

The court agreed, and noted the following in its order granting Summary Judgment in favor of the debt collector: