FDCPA · TCPA · State-Specific · SOC 2

    AI Past-Due Collection Calls for US Lenders

    FDCPA + TCPA-compliant outbound for 1-90+ DPD accounts. Mini-Miranda automated. Real-time cease-communication. Mid-call payment-link delivery. 32% lift in soft-bucket cure.

    For consumer lenders, BNPL platforms, auto finance, credit unions, debt-buyers and servicers. SOC 2 Type II.

    By DPD Bucket — Production Benchmarks

    Cure rates from live US lender deployments (consumer credit + BNPL + auto). Cost is fully-loaded per contact including FDCPA scaffolding and audit trail.

    1–30 DPD
    Early-stage
    55–68% cure
    $0.55–$0.85 per contact

    Conversational reminder with payment-link delivery. Most cures here are willingness-to-pay issues, not ability-to-pay.

    31–60 DPD
    Soft bucket
    28–38% cure
    $0.65–$1.10 per contact

    Negotiation flow — payment plan offers, hardship modules, settlement floors. Where AI vs human cure rate gap is narrowest.

    61–90 DPD
    Mid bucket
    12–22% cure
    $0.85–$1.40 per contact

    Promise-to-pay validation, financial hardship intake, escalation to live agent for complex cases.

    91+ DPD
    Legal-track
    4–11% cure
    $0.95–$1.85 per contact

    Pre-charge-off outreach, settlement offers, soft handoff to legal recovery. Tight FDCPA scripts mandatory.

    Compliance Stack — Audit-Ready From Day One

    Three regulatory layers built into the dial pipeline, not bolted on. The per-call audit row is designed to satisfy a CFPB inquiry or a TCPA defense.

    FDCPA — Federal
    • Mini-Miranda script in opening utterance ("This is an attempt to collect a debt...")
    • Validation notice — written followup within 5 days of initial contact
    • 8am-9pm recipient local time enforcement
    • Cease-communication request honoured immediately (real-time opt-out)
    • No misrepresentation: AI identifies as a representative, not a human
    • Third-party disclosure prohibited — only debtor or spouse/authorized party
    TCPA — Express Consent
    • Express written consent capture at account origination
    • Per-call consent validation before dialing
    • DNC (federal + state) scrubbing at dial-time
    • State-specific calling-window override grid (NY, CA, FL, TX, IL stricter)
    • Court-admissible audit trail per call
    • Mobile-vs-landline routing logic (some states differentiate)
    State-Specific Add-Ons
    • CA Rosenthal Act — broader "debt collector" definition than FDCPA
    • NY UCC enforcement requirements for licensed servicers
    • TX Finance Code §392 + state-licensing carve-outs
    • FL CCPA cease-communication faster propagation
    • WA, MA, IL custom calling-window grids
    • DC, MD additional disclosure language

    Collections FAQ

    Is AI collection calling FDCPA-compliant?

    Yes — Caller Digital's collection flow is built around the FDCPA from the script template up. Mini-Miranda fires in the opening utterance of every call ("This is an attempt to collect a debt; any information obtained will be used for that purpose. This call is being recorded."). The 5-day validation notice is automated via SMS/email after first contact. Cease-communication requests are honoured in real-time — the moment the debtor says "stop calling" the dial pipeline suppresses further contact within seconds, with the suppression audit-logged. Third-party disclosure rules are baked into the script: the AI does not discuss debt with anyone other than the debtor or a verified authorized party. Calling-window enforcement (8am-9pm recipient local time) is automatic.

    What does Mini-Miranda look like in an AI voice agent script?

    Mini-Miranda is the opening disclosure required on every FDCPA-regulated collection call. In Caller Digital's standard US collections deployment, the AI's opening utterance is: "Hello, this is [Agent Name] calling from [Servicer Name]. This is an attempt to collect a debt; any information obtained will be used for that purpose. This call is being recorded. May I please speak with [Debtor First Name]?" The full text is registered in the script template, fires before any debt-related ask, and the timestamp of disclosure is captured in the per-call audit row. The 30-second opening clip is reviewable in the audit export — useful if a TCPA / FDCPA defense is ever filed.

    How does the AI handle cease-communication requests under FDCPA §1692c(c)?

    Real-time suppression. The AI's NLU is tuned to recognize cease-communication language broadly — not just "stop calling" but also "don't call me again," "remove me from your list," "I'm asking you to stop," etc. The moment recognized, the AI confirms ("I understand — we'll stop calling you. You may still receive a written notice.") and writes a cease-communication flag to the account record. The dial pipeline picks up the flag within 60 seconds across all queues. Any subsequent dial attempt against that account is suppressed and audit-logged as a suppression event. Most state-level cease requirements have shorter propagation windows than the FDCPA's 30-day; Caller Digital's 60-second propagation satisfies all known state requirements.

    What is the production-grade cure-rate lift on soft-bucket collections (31-60 DPD)?

    Soft-bucket (31-60 DPD) cure rate lifts measured across US lender deployments: baseline (human-only call center) typically 22-28%; with AI augmentation 28-38%. The lift is 32% in aggregate. Drivers: AI reaches 78-85% of accounts vs 45-55% for human-only (which run business hours only); AI offers consistent payment plans without negotiator variance; payment-link delivery mid-call captures 18-24% of cures that would otherwise require a callback. Cost per cure: $1.85-$3.50 fully loaded (AI platform + telephony + supervisor overhead + payment-link processing) vs $7-$15 for human-only soft-bucket cure. Net annual savings on a 50k-account book typically run $850k-$1.8M.

    Can the AI deliver a payment link mid-call?

    Yes. Caller Digital integrates with the major US payment processors (Stripe, Adyen, Authorize.Net, Plaid Pay, Spreedly) and the major lender-built payment portals. Mid-call, the AI offers "I can text you a secure payment link right now — would that be helpful?" If the debtor agrees, the AI fires the link via SMS to the registered mobile, walks through the steps as the debtor opens it, and validates the payment confirmation within the same call. Payment completion rate when offered mid-call: 24-32% vs 8-14% for follow-up SMS without the verbal walkthrough. For ACH-only debt-products, the AI captures bank-account information via DTMF entry (PCI-DSS Level 1 compliant) rather than spoken digits.

    Does the AI handle state-specific licensing and calling-window grids?

    Yes. For US deployments, Caller Digital maintains a state-by-state grid covering: licensing requirements (CA, NY, TX, FL, etc.), state-specific calling windows (CA: 8am-9pm with stricter weekend rules, NY: 8am-9pm, FL: 8am-9pm with no-Sunday for some debt classes), additional disclosure requirements (DC, MD), and cease-communication propagation requirements. The dial pipeline filters each contact against the recipient's state-of-residence (from address on file) and the licensed-state list for the calling entity. Calls to states where the lender isn't licensed are suppressed at dial-time, not retroactively. The compliance grid is updated quarterly with regulatory changes.

    How does pricing work for FDCPA-compliant AI collection calls?

    Outcome-based USD pricing per past-due account contact. 1-60 DPD (soft bucket): $0.55-$1.10 per contact. 61+ DPD (mid + legal-track): $0.95-$1.85 per contact. "Contact" = AI reached the debtor (or verified authorized party) and completed the structured FDCPA conversation. No-answer attempts don't bill. Cease-communication suppressions don't bill on subsequent attempts. Voicemail with permitted message bills at the contact rate only when the debtor returns the call; otherwise it doesn't bill. Volume tiers: under 25k contacts/month at upper end, 250k+/month at lower end with Enterprise pricing. All pricing includes FDCPA + TCPA compliance scaffolding, SOC 2 attestation, mini-Miranda + cease-communication automation, and per-call audit trail retention for 7 years.

    Pilot Soft-Bucket on 5k Accounts

    30-day pilot. FDCPA + TCPA scripted, your CRM, your payment processor. Cure-rate lift report at day 30.

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