[Send2k1]

When a Bank assigns charged-off balances to a third-party debt collector, is it ok to require that customer work only with that agent?
Requirement to work directly with agent would include turning away a customer desiring to make a payment in branch.
It seems that we are allowed to designate payment location, with notice of course.

Practice would be uniform across markets; accounts are assigned to debt collector based on consistent credit risk analysis and all would be treated the same – seeming to limit Fair lending concern.
Vendor Management oversight expectation is understood; contract to address FDCPA compliance requirements, Monitoring for complaints, etc.
Insights on other considerations appreciated.

[jholzknecht]

You have considered all of the major issues. Some lenders are happy to get a payment on a charged-off loan from any source. Accepting a payment directly from the consumer generally triggers payment adjustments under the terms of your contract with the collector. Requiring the consumer to deal directly with the collector eliminates that burden. As long as you have addressed the issues listed in your question and the language of your note or loan agreement doesn’t prohibit you from requiring payments be made to the collector, which would be highly unusual, you should be fine.

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