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 licensing covers every state, 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 · April 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 by construction
Validation notices auto-generate at placement. Time-of-day windows enforced server-side. Counsel firewall halts outreach on detection. We cannot bypass these; they're wired into the code path.
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. State licensing expansion follows pilot footprint.
State-by-state, where we can operate today.
Debt Digest provides shared receivables workflow software. Legal status and licensing duties depend on each participant’s actual conduct, authority, contracts, account context, and jurisdiction. Where analysis is incomplete, we say so and hold activation. The current federal and state review lives on /legal.
| State | Posture | Notes |
|---|---|---|
| Texas | Live | Primary pilot footprint. Participant- and conduct-specific analysis under Tex. Fin. Code Ch. 392 remains subject to documented counsel review before activation. |
| Georgia | Live | Participant- and conduct-specific analysis under O.C.G.A. § 7-3-26 remains subject to documented counsel review before activation. |
| Ohio | Live | Participant- and conduct-specific analysis under Ohio Rev. Code Ch. 1349 remains subject to documented counsel review before activation. |
| Florida | Evaluated | Bond and notice requirement under Fla. Stat. § 559.553 evaluated. Filing path scoped; we file once a Florida pilot creditor is signed. |
| North Carolina | Evaluated | Permit requirement under N.C. Gen. Stat. § 58-70-1 et seq. evaluated. Counsel opinion on the planned participant roles and conduct is pending. |
| New York | Evaluated | NYC Department of Consumer Worker Protection license required for any borrower contact in NYC. Filing path scoped, not yet submitted. We will not place NY accounts before license is in hand. |
| California | Evaluated | CA Debt Collection Licensing Act applicability is under review by participant role and actual conduct. No exclusion or filing decision is assumed until the written analysis is complete. |
| All other states | Following pilots | License path is evaluated when a pilot creditor in that state is signed. We do not pre-clear states speculatively because counsel cost compounds without revenue. |
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 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
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.
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.
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.