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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.
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