Regulatory posture, written for review.
In plain terms: Debt Digest makes the software; the lender remains the party of record for any contact with a customer. The detail below is for your legal team.
This page documents Debt Digest, Inc.’s regulatory identity as a technology service provider on the live product, how the FDCPA §1692e(11) Mini-Miranda is handled as the customer’s obligation where it is required, the privacy and terms framework that governs the platform, and the consumer-rights surface the platform supports under the FDCPA and Regulation F. It is the single source of legal posture for a buyer’s legal department evaluating the platform.
The Mini-Miranda is the customer’s obligation, applied per (customer × state).
The FDCPA §1692e(11) Mini-Miranda is an obligation of the party of record, the lender or its collector, never of Debt Digest. Debt Digest is a technology service provider and is not a debt collector under §1692a(6), so it would never make a demand in its own name. The platform inserts the §1692e(11) string into a customer’s communication only where that customer’s (customer × state) configuration resolves to “Mini-Miranda required,” under the customer’s direction. The matrix below is the operational rule.
The Mini-Miranda is per-account, the customer’s obligation, not per-footer.
FDCPA §1692e(11) Mini-Miranda
FDCPA §1692a(6) DD outside the definition
Reg F §1006.2(e) Service provider
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 a customer’s communication only where that customer’s (customer × state) configuration resolves to “Mini-Miranda required,” under the customer’s direction. It is not a global default, and Debt Digest never speaks the string in its own name, because Debt Digest is a technology service provider that hosts data and transmits at the customer’s direction, not a debt collector under §1692a(6).
Service provider · 30–119 DPD · lender-owned
The debt was not in default at the time of placement, and the lender remains the party of record. Debt Digest hosts the data and transmits at the lender’s direction; it is outside the “debt collector” definition of 15 U.S.C. §1692a(6) altogether and makes no demand in its own name. Whether the §1692e(11) string is required is the lender’s determination per its (customer × state) configuration; sender identification names the credit union.
Software vendor / intermediary · not a party to the debt
Not a “debt collector” under §1692a(6); the platform facilitates communications between the parties who are. The creditor or the settlement firm on the other side is the regulated party of record. The platform supports those parties’ Reg F obligations (communication logging, opt-out routing).
Discharged debt
If a consumer has received a bankruptcy discharge of the underlying debt, no communication from Debt Digest is an attempt to collect that debt; communications are for informational purposes only. Account scrubbing against the National Consumer Bankruptcy Registry is performed at every batch upload.
Counsel-supervised, named in advance, outside the platform entity
Debt Digest, Inc. is a technology service provider and does not hold debt collector status. If at any future date a line of business would require FDCPA debt collector status, that activity is ring-fenced in a separate entity as a customer of the platform, event-gated, counsel-supervised, and logged in the audit trail. The Mini-Miranda would apply only to that entity’s accounts and would not be retroactive to Intercept accounts. Any such change is named in advance, not a quiet drift.
Implementation. The Mini-Miranda string is produced at the account level by the FDCPA-notice generator, not as a uniform footer or page-level disclaimer. Audit-log entries capture (creditor_id, state, mini_miranda_produced: boolean) on every initial communication and every meaningful subsequent contact, 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.
Debt Digest is a technology service provider, outside the FDCPA §1692a(6) definition.
The live product is the Intercept pre-charge-off workflow. Debt Digest hosts the data and transmits at the lender’s direction; the lender remains the party of record. Debt Digest sits outside the §1692a(6) “debt collector” definition altogether, not inside an exemption to it: it is a service provider under Reg F §1006.2(e), CFPA §5481(26), and CCPA §1798.140. The table below is the operational identity for the live product.
| Product | Regulatory identity | FDCPA status | Reg F status |
|---|---|---|---|
| Intercept30–119 DPD · lender remains party of record | Technology service provider to the lender; not an agent or servicer in the consumer-facing relationship | Outside the §1692a(6) “debt collector” definition altogether: hosts data and transmits at the lender’s direction, makes no demand in its own name. Reg F preamble (85 Fed. Reg. 76734, 76749–76750) recognizes the technology vendor as a non-collector category; consistent with the textualist read in Henson v. Santander, 137 S. Ct. 1718 (2017). | Service provider under 12 CFR §1006.2(e). The platform supports the lender’s Reg F obligations: §1006.6 time-of-day windows and §1006.14 harassment prohibitions are enforced server-side. |
| Resolvesettlement rail | Software vendor & intermediary; not a party to the underlying debt | Not a “debt collector” under §1692a(6); the creditor or firm on the other side is the regulated party of record. | Not directly applicable; the platform supports the parties’ Reg F obligations. |
State-conduct note: the §1692a(6) analysis is federal. Some state statutes (for example Tex. Fin. Code Ch. 392, O.C.G.A. §7-3-26, Ohio Rev. Code Ch. 1349, Cal. Fin. Code §100000 DCLA, Cal. Civ. Code §1788 Rosenthal) define “debt collector” or “collection activity” more broadly. The state-by-state analysis under the service-provider posture is in progress with counsel; no filing decision is treated as settled until that analysis is in hand.
Federal statutes that bind us regardless of FDCPA identity.
These obligations are independent of “debt collector” status and apply to the platform on every account.
GLBA §6801 Customer info / safeguards
NCUA 12 CFR 748 Service-provider posture
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
FDCPA §805(a)(2)
NDR firewall
Counsel / NDR firewall is code-level, not policy-level.
Where Debt Digest has actual knowledge that a consumer is represented by counsel or an NDR firm, all direct outreach is suspended and routed to the creditor for handling. The firewall is enforced at outreach time on a representation_status flag and produces an audit_log row with event_type = "firewall_suppression" and the trigger source. Suppression sources: (a) creditor notice; (b) consumer self-identification in portal; (c) inbound communication from counsel; (d) match against the internal representation overlap list.
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. Each item is enforced at the code path level and logged in the audit trail.
Right to dispute (FDCPA §1692g; Reg F §1006.34(c)(4))
A consumer may dispute all or part of a debt within 30 days of receiving the validation notice. A dispute received within the Reg F validation period triggers an immediate 30-day collection pause on the account, server-enforced and not overridable by staff. The pause persists until verification is provided.
Right to validation (FDCPA §809(a); Reg F §1006.34(a)(1)(i))
An FDCPA §809(a) validation notice is generated on initial communication where Mini-Miranda is required (see matrix above). Delivery is within five days of initial communication. Content includes §1006.34(c) itemization and §1006.34(d) consumer rights statement. Electronic delivery requires E-SIGN consent. Re-delivery occurs on bounce.
Right to cease communication (FDCPA §1692c(c))
Cease-communication requests are honored within one business day of receipt and surfaced to the creditor within 24 hours on demand. All requests are recorded in the Cease-Comm Log.
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.
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; process payments and settlement offers; 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 (e.g., Stripe) to process payments; with service providers who assist in delivering the platform (e.g., email delivery); 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.
About the Service
Debt Digest provides software and technology-service-provider services that creditors configure for their accounts. We are not a lender, we do not extend credit, and we are not a debt collector. The creditor of record approves settlement terms, discount percentages, payment timelines, and launch workflows, which may vary by pilot or account placement.
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
Payments processed through the Service are handled by our payment provider, Stripe. By making a payment, you authorize the charge to your designated payment method. All payments are applied to your account in accordance with the agreed settlement plan. Payment confirmations are sent electronically. The customer pays the creditor; the creditor pays Debt Digest for the platform. Debt Digest does not custody member funds.
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. Response SLA is two business days for non-urgent inquiries; immediate for regulator forwarding.
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, pen-test summary).
Regulator forwarding
If you are forwarding a regulator inquiry, email compliance@debt-digest.com. We acknowledge receipt within one business day and route to counsel of record.
Versioning & changelog.
Every material change to this page is dated. Counsel review status is tracked alongside each version.