Regulatory posture, written for review.
In plain terms: Debt Digest provides shared receivables workflow software. The account owner, sender, servicer, collector, firm, representative, and their authority are recorded separately for each workflow.
This page documents how the live product resolves participant identity and conduct, how the FDCPA §1692e(11) Mini-Miranda is applied when an identified sender and account require it, the privacy and terms framework governing the platform, and the consumer-rights controls the platform supports. It is the source of operating posture for legal review, not a substitute for participant counsel’s classification.
The Mini-Miranda is resolved per sender, account, and jurisdiction.
FDCPA §1692e(11) applies when a covered debt collector sends a covered communication. The platform does not infer legal status from a product label. It inserts the configured disclosure into a participant’s communication only where that participant’s (customer × state × account) rules require it. Actual conduct, role, contracts, account history, jurisdiction, and applicable law control the analysis.
The Mini-Miranda is a sender-and-account rule, not a universal page footer.
FDCPA §1692e(11) Mini-Miranda
FDCPA §1692a(6) Conduct-based definition
Reg F §1006.34 Validation information
Reg F §1006.18 False/misleading representations
“This is an attempt to collect a debt, and any information obtained will be used for that purpose.”
15 U.S.C. §1692e(11)The rule. The platform inserts the Mini-Miranda string into the identified sender’s communication only where the configured (customer × state × account) rule resolves to “Mini-Miranda required.” It is not a global default. Sender identity and applicable disclosures must be approved for each workflow before activation.
Lender-owned account · identified creditor sender
The creditor remains the account owner and approves each active workflow. The platform records sender identity, account history, and jurisdictional configuration. Whether §1692e(11) applies depends on the sender’s legal status and the communication’s facts; the platform does not decide that question from delinquency age alone.
Software vendor / intermediary · not a party to the debt
The platform facilitates communications among identified participants and is not a party to the underlying debt. Each creditor, collector, law firm, representative, and platform operator must be evaluated from its actual conduct and authority. The workflow supports participant-specific disclosures, communication logging, and opt-out routing.
Discharged debt
When a documented bankruptcy stay or discharge applies, collection workflows are held. Any permitted communication must be separately approved and informational in form. Screening occurs before placement, and an unavailable or inconclusive screening result fails closed.
Counsel-reviewed, named in advance, and configuration-gated
A new collection, servicing, ownership, representation, or marketplace role cannot inherit an old legal configuration. Activation requires a documented participant identity, authority model, jurisdictional review, sender/disclosure matrix, and audit event. Legal classification is never silently inferred from the platform entity or a marketing label.
Implementation. On the creditor rail the FDCPA §809(a) notice carries no §1692e(11) Mini-Miranda string. On the Layer 02 collector letter the string is required, and that letter is not produced for a §1692a(6) collector unless one is configured. Where the string is required, it is inserted on that communication, never as a uniform footer or page-level disclaimer. Audit-log entries capture the acting participant, the account and the timestamp, retained for the term and tail required by the pilot agreement.
Counsel review status. The conditional-Mini-Miranda position is operational and pending outside-counsel sign-off as enforced policy.
Legal duties follow actual conduct, authority, and account context.
Debt Digest supplies shared receivables workflow software. That operating fact does not itself decide whether any participant is a creditor, servicer, debt collector, representative, furnisher, or other regulated actor. The matrix records product facts and required controls; participant counsel determines legal classification from the specific workflow.
| Product | Operating facts | FDCPA analysis | Reg F controls |
|---|---|---|---|
| Interceptpre-charge-off · participant-specific authority | The account owner configures the workflow, approves sender identity, and authorizes outreach. Debt Digest hosts the record, enforces configured controls, and records actions. | Evaluate the account owner, assigned collector, firm, and platform conduct separately under §1692a(6), including account history, default status, authority, communications, and jurisdiction. No product-wide conclusion is asserted. | For covered workflows, the platform can enforce approved time windows, frequency controls, opt-outs, validation-information rules, disputes, and participant-specific disclosures. Counsel-approved configuration is required before activation. |
| Resolvesettlement rail | Software vendor & intermediary; not a party to the underlying debt | Evaluate each creditor, collector, law firm, consumer representative, and platform action from its actual role, authority, and communications. The rail does not transfer or erase a participant’s duties. | Participant-specific controls apply according to the approved workflow, including representation and cease-communication firewalls, communication logs, and validation-information handling. |
State-conduct note: federal and state definitions can differ materially. State licensing and conduct requirements are evaluated by participant type, account type, workflow, communications, and jurisdiction. No filing or exemption decision is treated as settled without documented counsel review.
Cross-cutting requirements are mapped independently of FDCPA status.
Privacy, security, communications, payments, credit reporting, military, bankruptcy, and unfair-practices duties are evaluated on their own terms for every participant and workflow.
GLBA §6801 Customer info / safeguards
NCUA 12 CFR 748 Vendor safeguards
TCPA §227 Prior express written consent
CAN-SPAM §7701 Email opt-out
CFPB UDAAP 12 U.S.C. §5531/5536
FCRA §1681 Furnisher / user duties
SCRA §3901 Servicemember scrub
11 U.S.C. §362 Bankruptcy stay
E-SIGN §7001 Electronic delivery consent
Firewall controls
FDCPA §805(a)(2)
NDR firewall
Counsel / NDR firewall is code-level, not policy-level.
Debt Digest operates a representation-matching control. Representing firms supply its entries; the identity fields on the account are what it matches against. Whether a specific consumer is represented within the meaning of FDCPA §805(a)(2) is a determination for the creditor, agency, or firm to make, not one this control makes for them; it does not limit any obligation arising from notice received by any other means. A send this control suppresses, whether on a confirmed match or a master-list lookup failure, is best-effort recorded in a dedicated firewall_blocks record (channel, reason, and the tenant that attempted contact), retained seven years, separate from the account's own audit trail. A send refused before any match is attempted, because the identity on the account is incomplete, writes no such record.
Consumer rights, surfaced as policy rather than legalese.
Below is the consumer-facing rights surface required under the FDCPA and Regulation F, reproduced for counsel review. Dispute holds, cease-communication requests, and validation-notice preparation follow the paths described in each card. Sending a notice, and whether a given account is covered, remain the identified participant's acts.
Consumer rights
Right to dispute (FDCPA §1692g; Reg F §1006.34(c)(4))
For covered accounts, a consumer may dispute all or part of a debt during the validation period. A timely qualifying dispute triggers an immediate collection hold that remains in force until verification is sent or another authorized, audited resolution is recorded. The 30-day period is the consumer response window, not an expiry date for the hold.
Right to validation (FDCPA §809(a); Reg F §1006.34(a)(1)(i))
Whether the platform prepares an FDCPA §809(a) validation notice at placement depends on the intake path and the account phase. The platform does not generate the §1006.34(c) itemization or the §1006.34(d) consumer rights statement in that letter. Preparation is not delivery. Sending the notice is the act of the participant that sends it, not an automatic platform schedule. The notice prepared on import carries the creditor of record, the amount of the debt, the account reference and the §1692g dispute and verification rights.
Right to cease communication (FDCPA §1692c(c))
A cease-communication request made in the consumer portal is recorded in the audit log, suppresses Debt Digest outbound email and text messages across the consumer's accounts at the time it is made, and notifies the creditor of record. Requests received off-platform are recorded by the participant that received them. All recorded requests appear in the Cease-Comm Log. The statute attaches no honor-by period.
No harassment (FDCPA §1692d; Reg F §1006.14)
No repeated-contact patterns. No threats of legal action not intended to be taken. No contact at inconvenient times. No third-party disclosures other than the creditor of record. Primary channel is the platform portal; the consumer controls the interaction.
Life-Happens protection
Penalty-free missed payments per year per plan, as configured by your creditor. Missed-payment balance redistributes across remaining months. Exceeding the configured allowance triggers plan-reset or escalation under the pilot agreement, not termination by default.
What we collect, how we use it, with whom we share it.
Debt Digest, Inc. (“Debt Digest,” “we,” “us,” or “our”) is committed to protecting personal information processed in the course of providing the platform. This Privacy Policy explains the categories of information collected, the purposes of processing, the basis for sharing, and the consumer rights available.
Privacy practices
Information We Collect
Information you provide directly: name, email address, phone number, mailing address, and the last four digits of your Social Security number (used solely for identity verification and account matching). Account information provided by your creditor: outstanding balance, creditor name, charge-off date, and account identifiers.
Automatically collected technical information when you use the platform: IP address (rate limiting and security), browser type, pages visited. We do not use tracking cookies for advertising purposes.
How We Use Your Information
To verify identity and match consumers to accounts; record settlement offers and, when payment processing is enabled, route consumer payments to the identified creditor; send legally required notices (including FDCPA validation notices); communicate about account status and payment options; comply with federal and state regulatory requirements; improve the platform.
We do not sell personal information. We do not use personal information for marketing of unrelated products.
Information Sharing
With the creditor of record as necessary to service the account; with payment processors (Stripe Connect) to route consumer payments to the identified creditor, and with email and SMS delivery providers, each of which is contracted but not yet enabled and receives no data today; with service providers who assist in delivering the platform; as required by law, regulation, or legal process; and to protect the rights, safety, or property of Debt Digest, our users, or the public. Service providers are contractually required to protect personal information and use it only for the purposes specified.
Data Security
Administrative, technical, and physical safeguards including encryption of data in transit (TLS 1.2+), secure password hashing, role-based access controls, server-enforced rate limiting, and audit logging of administrative access. Append-only audit log retained 36 months post-termination of the governing agreement.
Data Retention
Personal information is retained as long as necessary to fulfill the purposes described in this policy, comply with our legal obligations (including federal and state record-retention requirements for debt collection), resolve disputes, and enforce agreements. Retention is documented per record class in our internal data governance policy.
Consumer Rights and Choices
Consumers may request access to, correction of, or deletion of personal information by contacting privacy@debt-digest.com. Certain information may be retained as required by law. Non-essential communications may be opted out of at any time.
Platform terms governing use of Debt Digest.
By accessing or using the Debt Digest website and platform (the “Service”), you agree to these Terms of Service. If you do not agree, do not use the Service.
Platform terms
About the Service
Debt Digest provides shared receivables workflow software that participating organizations configure for their accounts. Debt Digest is not a lender and does not extend credit. Regulatory roles and duties depend on actual conduct, authority, contracts, account context, jurisdiction, and applicable law. The authorized account participant approves settlement terms, payment timelines, sender identity, and launch workflows.
Account Registration
To use certain features you must register an account. You agree to provide accurate information and keep credentials secure. You are responsible for all activity under your account. Notify us immediately at security@debt-digest.com if you suspect unauthorized access.
Payments
Live payment processing is not yet enabled: no production payment credential is configured, so no consumer payment is currently taken through the Service and the platform reports payment processing as simulated. The terms in this section govern payments once processing is enabled. When processing is enabled, Stripe Connect routes the consumer’s payment to the identified creditor or authorized payee. Debt Digest is not the payee and does not custody member funds. By submitting a payment you authorize the charge to your designated payment method for remittance to the creditor, and payments are applied to your account in accordance with the agreed settlement plan. The customer pays the creditor; the creditor pays Debt Digest for the platform. Payment confirmations are sent electronically.
Accuracy of Information
Reasonable efforts are made to ensure account information is accurate. If you believe any information is incorrect, you have the right to dispute. See “Consumer rights” above for the dispute procedure.
Limitation of Liability
Debt Digest provides the Service “as is.” We do not guarantee specific outcomes. Settlement offers and discount terms are subject to creditor approval and may change. To the maximum extent permitted by law, Debt Digest is not liable for indirect, incidental, or consequential damages arising from use of the Service.
Governing Law
These Terms are governed by the laws of the State of Delaware and applicable federal law, including the Fair Debt Collection Practices Act (FDCPA, 15 U.S.C. §1692 et seq.) and Regulation F (12 CFR Part 1006).
Where to send the redline, the diligence questionnaire, or the regulator forwarding.
Single counsel-facing channel for legal correspondence, diligence requests, and regulator forwarding. We target two business days for non-urgent inquiries; immediate for regulator forwarding.
Counsel contacts
Redline a pilot agreement
Email legal@debt-digest.com with your standard markup of the pilot agreement template. Reply within two business days.
Counsel of record
Outside compliance counsel engagement is in progress. Confirmed counsel of record is published on the Trust Center once the engagement letter is countersigned.
Diligence questionnaire
Email legal@debt-digest.com for the counsel-facing diligence packet (compliance framework, state licensing matrix, audit-log sample).
Regulator forwarding
If you are forwarding a regulator inquiry, email compliance@debt-digest.com. We acknowledge receipt within one business day and route to outside counsel at engagement.
Versioning & changelog.
Every material change to this page is dated. Counsel review status is tracked alongside each version.