No, they are not.
What are the TCPA’s restrictions on collection calls under FCC rules?
The FCC has determined that debt collection calls are not telemarketing calls. Therefore, under the rule the FCC has stated that with respect to autodialed or prerecorded debt collection calls, to the extent that they do not contain telemarketing messages, would not require any consent when made to residential wireline consumers, but require either prior written or oral consent if made to a consumer’s wireless number referring to 47 C.F.R. § 64.1200(a)(1).