What we know. What we're working on. Where the gaps are.
In plain terms: an honest snapshot of what Debt Digest can prove today, and what is still in progress.
This page is for the compliance and risk officer who has to sign off on us. We will not pretend the SOC 2 is finished, that our state-by-state conduct review is complete, or that our break-glass procedure is mature. Below is exactly where we stand, dated, with the documents you would need to redline our pilot agreement.
Posture · August 2026
Illustrative · live counts in the snapshot section below
What we will not change on you mid-pilot.
These are the institutional anchors. Everything else on this page is qualified by date and status. These four are not.
Member funds never touch us
Consumers pay the identified account owner or authorized payee. Participating organizations pay Debt Digest by subscription invoice. For currently activated direct-payment workflows, Debt Digest does not custody consumer funds. We host the shared record, enforce configured controls, and preserve the audit trail.
FDCPA + Reg F controls in the send path
Where the consumer’s state is on file, the text path holds a message outside that consumer’s local calling window; where it is not, an Eastern-time window applies as the fallback. It checks a §1692c(c) cease-communication mark before it sends. Where the identity fields are on file, the text path also checks the outbound against the §805(a)(2) representation list, and a representation block is written to its own firewall record with the channel and the tenant that attempted it.
Append-only audit log, exportable
Every state change emits a tamper-evident log entry. You can export the full chain for your portfolio in CSV at any time, with no gating and no notice required.
72-hour breach notification
If we detect an incident that may affect your data, you hear from us in writing within 72 hours of detection. Post-incident report within 30 days. Direct line to the on-call engineer during the active window.
Regulatory posture, today.
SOC 2 readiness work is underway in-house; we are not attested today. We are committed to additional certifications as we onboard customers who require them. Our per-state conduct review follows pilot footprint.
Available in every state. Reviewed state by state.
Debt Digest is receivables workflow software. It does not collect, does not contact consumers in its own name, and holds no state collection license; in each state we review whether one is needed before a customer goes live. Federal status is settled by conduct, not by category. State statutes are a separate question because some define collection activity more broadly than federal law, so we review each state on the same two questions: does the statute reach what the software actually does, and which licenses does the customer using it there already carry. Where a review is still open we say so. The current federal and state analysis lives on /legal.
| State | Our conduct review | What it found, and who carries the license |
|---|---|---|
| Texas | Reviewed in-house | Primary pilot footprint. Our working analysis, not yet counsel-confirmed, is that under Tex. Fin. Code Ch. 392 the software is not a person engaged in debt collection: a creditor is first-party on its own debt, and an agency or firm customer carries its own registration. The rescoped opinion goes to outside counsel at the first pilot signature in this state. |
| Georgia | Reviewed in-house | Our working analysis, not yet counsel-confirmed, is that under O.C.G.A. § 7-3-26 the software is not a person engaged in the collection of consumer debt. Any collection licensing sits with the customer acting on the accounts. The rescoped opinion goes to outside counsel at the first pilot signature in this state. |
| Ohio | Reviewed in-house | Our working analysis, not yet counsel-confirmed, is that under Ohio Rev. Code Ch. 1349 and Ch. 4710 the software is outside both the collection and the debt-adjustment definitions: it never holds consumer funds and never demands payment in its own name. The rescoped opinion goes to outside counsel at the first pilot signature in this state. |
| Florida | Under review | Fla. Stat. § 559.553 registers consumer collection agencies. An agency customer holds that registration; a creditor customer is first-party. Whether any reading of the statute reaches the software itself is the open question, and we write it down before a Florida customer goes live. |
| North Carolina | Under review | N.C. Gen. Stat. § 58-70-1 et seq. permits collection agencies. The customer acting on accounts carries the permit. The written analysis of whether the statute reaches the software is open. |
| New York | Under review | N.Y. Gen. Bus. Law § 600 and the NYC Department of Consumer and Worker Protection license attach to the party contacting the consumer, which is the customer. Section 600 can also be read to reach a facilitator, which is why New York stays Under review until the written answer lands, before any New York customer goes live. |
| California | Under review | The Debt Collection Licensing Act licenses debt collectors. A creditor customer is first-party on its own debt and an agency customer holds its own DFPI license. Whether the Act reaches a workflow vendor by conduct is under written review; we assume neither an exclusion nor a filing until it is complete. |
| All other states | Reviewed at first customer | The software is available. The per-state written review is completed when the first customer in that state signs, because that is when the participant roles and conduct in that state are concrete rather than hypothetical. |
Prepared and maintained in-house against current state law. Submitted for outside-counsel review at the first pilot signature in a given state, and revisited on any state regulatory action.
The questions we want compliance officers to ask first.
If a vendor doesn't surface these for you, they're either young enough not to have thought about them or mature enough to be hiding them. We are the first. Here are the honest answers.
The work in progress, named.
A vendor who claims no gaps is a vendor who hasn't audited themselves. Here are ours, what's in motion, and when we expect each to clear.
Who supervises this, and which statutes we operate under.
Pilot agreement redlines are welcome. Once counsel is retained at signature, our counsel and your counsel speak directly; we don't sit between them.
Counsel contacts
Counsel of record
Outside compliance counsel is retained at defined triggers, the first of which is a first pilot signature. The scope is already set: FDCPA and Reg F posture, charge-off timing (NCUA 12 CFR 741.3 for credit unions, FFIEC URCC for banks), and state-licensing matters. That analysis is drafted and dispatch-ready today. Firm name is disclosed under NDA during diligence once the engagement letter is countersigned.
Redline our pilot agreement
Send your standard markup to legal@debt-digest.com. We turn redlines within five business days. Non-trivial changes are held for outside-counsel review at engagement.
Statute index
FDCPA §809(a) Applicable validation-notice workflow
FDCPA §805(a)(2) Counsel firewall
FDCPA §1692c(c) Cease-communication, one-click
Reg F §1006.6 Outreach time-of-day windows
Reg F §1006.34 Applicable validation information and itemization
NCUA 12 CFR 741.3 120-DPD charge-off boundary (credit unions)
OCC / FFIEC 180-day charge-off boundary (banks)
RFC 9116 security.txt disclosure contact
Transport & infrastructure controls
TLS 1.3 All traffic encrypted in transit
HSTS Strict-Transport-Security enforced
Hosted compute SOC 2 Type II sub-processor
Managed Postgres SOC 2 Type II sub-processor
Source control and CI SOC 2 Type II sub-processor
For the printable one-page packet with the encryption controls and sub-processor categories, see /security.
What changed on this page, when.
Material edits to commitments, licensing posture, or counsel are dated below. Cosmetic edits are not.
For diligence, procurement, and integration.
If you need the printable vendor packet, start at /security. The tiles below cover everything else compliance and engineering will likely ask for.
Diligence documents
Vendor packet
Printable one-pager. Encryption, sub-processors, controls.
Open →API reference
Endpoints, authentication, error codes, sample payloads.
Open →Webhook verification
HMAC-SHA256 signature validation. Retry policy. Event schema.
Open →Legal & privacy
Terms of service, privacy policy, member rights, data export.
Open →How member data moves through us, and what happens if something breaks.
The printable controls list lives on /security. The posture statements below describe what we will and will not do with your members' data.
How member data moves
FDCPA §809 Validation
Reg F §1006.6 Quiet hours
FDCPA §805(a)(2) Counsel firewall
Member data flows through one tenant boundary per creditor.
PII firewalls are enforced at the database query layer, not application policy. A creditor cannot read another creditor's members. We never sell data. We never share member PII across pilots. Minimum-necessary is the rule: last-4 SSN where ID verification requires it; full SSN never requested for servicing. Closed accounts anonymized after 7 years per FDCPA record-keeping norms. Creditors can export their full audit log and portfolio in CSV at any time, with no gating.
GDPR / NCUA 72-hour notice
RFC 9116 security.txt
If we detect an incident, you hear from us in writing within 72 hours.
Post-incident report within 30 days covers root cause, scope, remediation, and prevention. You get direct access to the on-call engineer during the active window. Security contact: security@debt-digest.com. Coordinated-disclosure contact is published at /.well-known/security.txt per RFC 9116.
Bring your hardest compliance question.
We would rather you ask now and walk away than learn the answer in month three of a pilot. If we have not addressed it on this page, send it directly.