Over the last couple of weeks, we’ve featured many of the changes for collections agencies that were rolled out through Regulation F. These changes were part of an amendment proposed by the Bureau of Consumer Financial Protection (CFPB), a U.S. government agency in charge of ensuring banks, lenders, and other financial companies treat their customers fairly.
These changes became effective on November 30th and changed the way debt collection agencies operate. One of the most significant shifts affects the dates that debt collectors can contact consumers. If an agency does not comply with these specific changes, they face huge penalties or lawsuits.
We understand that the changes can be challenging to mitigate for our clients, particularly if they’re used to contacting consumers using different time stamps and methods. With this in mind, here’s more information about the Itemization Date of a Debt and how companies can move forward with selecting the date that will work best for their collection goals.
What is the Itemization Date of a Debt?
To clarify, the term Itemization of a Date refers to one of five possible dates the debt collector can use to discover the amount of the debt owed on that date. The new changes to Regulation F that went into effect on November 30th allow a collector to choose which one of those five possible dates the debt collector can accurately recite the amount of debt to the consumer on that date. These dates include:
1) Last statement date: This is the last day of your billing cycle and typically occurs about 21 days before your payment due date
2) Charge off date: The date on which a creditor writes an uncollectible debt off its books. The charge-off date falls 180 days after the last payment made by a delinquent debtor. At that point, the creditor has determined that it will no longer receive any payment from the debtor.
3) Last Payment Date: The previous date the last payment was made
4) Transaction date: The actual date that a specific type of financial transaction took place.
5) Judgement date: The date of rendition of the judgment, which is the day when the judgment is signed by the judge and filed with the clerk of court
Which Itemization Date to Use
How does a debt collector decide which of the itemization dates to use? The most important thing a debt collector can consider to choose which itemization dates to use is to ask, “Which information can I get most consistently, reliably, and most accurately from each one of that collector’s clients?” The answer to this question may change based on each client and each portfolio for a debt collection agency, which is why the ability to choose one of the dates listed above is so imperative.
Capital Recovery Partners’ Approach to Itemization Date
As a leader in the debt collections industry, Capital Recovery specifically focuses on two of the five itemization dates available to collections agencies, the charge-off date, and the transaction date. For our team, we feel that using these two dates allows us to continue to grow and develop into one of the best debt collection agencies in the world. Our specialized medical and commercial debt collectors are assigned to accounts based on the knowledge of the business. This allows us to continue to serve our clients with unparalleled performance.
To learn more about how our company can help you establish an internal recovery system or provide business debt collection to your company, reach out to start a conversation with our team today.