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CollectionsIf your agencies call your customers, you need to know how they count. Here's what Regulation F's 7-in-7 test includes, what it leaves out, and the records that prove it.
Regulation F presumes a debt collector complies with its ban on harassing calls if it calls a person about a particular debt no more than 7 times in 7 consecutive days and doesn't call within 7 days after a phone conversation about that debt (12 CFR 1006.14(b)(2)). Unanswered calls and voicemails count. The count runs separately for each debt.
Where the rule stands
General information, current as of Nov 2, 2026. It isn't legal advice. Rules change and differ by state, so check the sources linked here and talk to your own counsel before you act on it.
TSI (Transworld Systems Inc.) publishes it. TSI provides Accounts Receivable Management (ARM), Healthcare Revenue Cycle Management (RCM), CXBPO and Loan Servicing (via UAS). DebtNext, a TSI company, makes recovery management software for creditors. Some options this page describes compete with services TSI sells. Each figure names its publisher and date so you can check it yourself.
Regulation F is the CFPB rule that carries out the Fair Debt Collection Practices Act (FDCPA). It's at 12 CFR part 1006 and took effect Nov 30, 2021. It covers debt collectors under the FDCPA, mostly third-party collection agencies and debt buyers collecting consumer debts. It sets rules for calls, emails, texts and social media, validation notices, and credit reporting before contact. The 7-in-7 call limit is one part of it. The Federal Reserve's Regulation F on interbank liabilities is a different rule.
Section 1006.14(b)(1) bars a debt collector from placing calls "repeatedly or continuously with intent to annoy, abuse, or harass any person at the called number." The 7-in-7 test in 1006.14(b)(2) sets 2 presumptions on top of that ban.
A collector is presumed to comply if it calls a person about a particular debt no more than 7 times within 7 consecutive days, and doesn't call again within 7 consecutive days after a phone conversation about that debt (1006.14(b)(2)(i)). Going past either limit creates a presumption of a violation (1006.14(b)(2)(ii)).
Evidence can rebut either presumption. The CFPB's official interpretations list the factors (comments 14(b)(2)(i)-2 and 14(b)(2)(ii)-2).
A call counts once it connects to the dialed number, unless an exclusion applies (comment 14(b)(3)(ii)-1).
| Call outcome | Counts toward 7-in-7? | Source |
|---|---|---|
| Answered, even if it drops | Yes | Comment 14(b)(3)(ii)-1 |
| Rings with no answer | Yes | Comment 14(b)(3)(ii)-1 |
| Reaches voicemail, even with no message left | Yes | Comment 14(b)(3)(ii)-1 |
| Ringless voicemail | Yes | Comment 14(b)-1 |
| Busy signal or number not in service | No | 12 CFR 1006.14(b)(3)(ii) |
| Text message or email | No | Comment 14(b)-1 |
| Placed with the person's prior consent, given directly to the collector | No, for up to 7 days | 12 CFR 1006.14(b)(3)(i) |
| Placed to the consumer's attorney, a consumer reporting agency, the creditor, or the creditor's or collector's attorney | No | 12 CFR 1006.14(b)(3)(iii) and 1006.6(d)(1)(ii)-(vi) |
| Placed to a number the collector later learns isn't the person's | No, for that person | Comment 14(b)(2)(i)-3 |
Texts and emails sit outside the count, and the harassment standard in 1006.14(a) still covers them. In the CFPB's example, 7 unanswered calls in 7 days plus multiple unsolicited emails the consumer never answers are "likely" harassment, even though the calls stay within the limit (comment 14(a)-2).
"Particular debt means each of a consumer's debts in collection" (1006.14(b)(4)). Student loans are the exception: all student loans serviced under a single account number when the collector obtained them count as 1 debt.
A call in which the collector discusses 2 debts, or leaves a voicemail about both, counts toward each of them. An unanswered call, or a call where no particular debt comes up, counts toward at least 1 debt (comment 14(b)(4)-1).
The count also runs per person. Calls to a third party to find the consumer have their own count (comment 14(b)(2)(i)-1.iii), and 1006.10(c) generally allows only 1 location communication with that person.
The pattern test still applies across all of those calls. The CFPB lists "seven telephone calls to the same telephone number within one day" as a pattern that can rebut the presumption of compliance (comment 14(b)(2)(i)-2.i).
A phone conversation about a debt starts a 7-day quiet period for that debt, and the day of the conversation is day 1 (1006.14(b)(2)(i)(B)). In the CFPB's example, after a conversation on Friday, August 14, another call about that debt before Friday, August 21 is presumed to violate the rule (comment 14(b)(2)(ii)-1.ii).
The quiet period attaches to the debt that was discussed. A conversation only about a medical debt starts no quiet period for a credit card debt the same consumer owes (comment 14(b)(4)-2.iii).
Calls placed with the person's prior consent fall outside the count if the consent was "given directly to the debt collector" (1006.14(b)(3)(i)). A collector "cannot rely on the prior consent of the consumer given to a creditor or to a previous debt collector" (comment 6(b)(4)(i)-2).
Consent covers calls about that debt for up to 7 consecutive days, starting the day the collector receives it. It ends sooner if the person set a shorter window, revokes it, or has a phone conversation with the collector about the debt (comment 14(b)(3)(i)-2).
In the CFPB's example, a consumer emails on Thursday, June 4 asking for a call about repayment options. 8 unanswered calls from June 8 to June 10 fall outside the count, and calls on or after June 11 count again (comment 14(b)(3)(i)-3.iii).
Consent to more calls is separate from consent to call at other times. Unless the collector knows otherwise, calls before 8 a.m. or after 9 p.m. at the consumer's location are inconvenient (1006.6(b)(1)(i)), and consent to another time has to come directly from the consumer (1006.6(b)(4)(i)). A request to stop using the phone still binds the collector (1006.14(h)). Comment 14(b)(3)(i)-1 says the consent exclusion permits nothing those sections prohibit.
Consent to autodialed or prerecorded calls under the TCPA (47 CFR 64.1200) is a different question, with its own revocation rules. The FCC changed those rules in an order adopted Sep 30, 2026, which takes effect Nov 25, 2026; TSI's TCPA consent revocation brief covers it.
When either presumption is tested, "it is assumed that debt collectors intend the natural consequence of their actions" (comments 14(b)(2)(i)-2 and 14(b)(2)(ii)-2).
| Presumption | Factors the CFPB lists |
|---|---|
| Compliance (calls within 7-in-7) | Calls in rapid succession, such as "two unanswered telephone calls to the same telephone number within five minutes"; heavily concentrated calls or voicemails; the person's earlier statement that they don't want contact, won't pay or don't owe the debt; a cease-communication notice or a request to stop phone calls; the collector's past conduct, such as abusive language or calls at inconvenient times |
| Violation (calls over 7-in-7) | A call required by law, such as a mortgage loss-mitigation call under 12 CFR 1024.39(a); a call directly tied to active litigation on the debt; a call answering the consumer's request for information when the consent exclusion didn't apply; a time-sensitive call that lets the consumer avoid a harm outside the collector's control, such as a creditor's late fee |
A deadline the collector invents doesn't qualify. The CFPB's example is a "one-time only" discount that the collector could have offered through the end of the month (comment 14(b)(2)(ii)-2.iv).
Meeting 1006.14(b) settles call frequency only (comment 14(b)(1)-1). What a call says, and the combined effect of calls, texts and emails, are judged under 1006.14(a).
A collector must keep records that are "evidence of compliance or noncompliance" from the start of collection activity on a debt "until three years after the debt collector's last collection activity on the debt" (1006.100(a)). The CFPB names "telephone call logs" as one of those records (comment 100(a)-1).
Recording calls is optional: "Nothing in § 1006.100 requires a debt collector to record telephone calls" (comment 100(b)-1). A collector that does record must keep each recording "for three years after the date of the call" (1006.100(b)).
To show the count for each debt, a call log needs:
Creditors that place accounts can test an agency's counting with 6 questions.
Some jurisdictions set tighter limits. From Jan 1, 2027, New York City's SHIELD Rule limits communications and attempts to 3 per account in 7 days across all media except mail, with some exceptions (NYC DCWP FAQ, Aug 4, 2026).
Count every call attempt per person and per debt in the dialer, and block a call before it dials if it would break a limit. Review texts and emails with calls, because 1006.14(a) judges their combined effect. Then check the conversations themselves. At TSI, dial restrictions are set by client and by jurisdiction, and Ripple scores every call. Ask your agencies for the same evidence: how they count, their exception reports and a sample of scored calls.
TSI's collection system applies dial restrictions that limit how often, and at what times, calls can be placed. Restrictions can be set by client and by jurisdiction, in third-party collections and other ARM programs.
Use this checklist with your own call logs and your agencies' reports.
Dated Nov 2, 2026. Built on 12 CFR 1006.14 and 1006.100 and the CFPB's official interpretations as in force on that date. Tick each box only when you've seen the evidence in your own system or your agency's report.
Checked by: ____________________ Date: ____________
This page replaces TSI's Mar 24, 2026 post on Regulation F. We corrected 4 statements from it:
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