And, since you are dealing with third parties who are subject to the rule in their roles, you have to ensure that those third parties will comply with the rule when it's effective. Of course, since the FDCPA has itself been in effect for years, you should be ensuring their compliance with the law now.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8