Secondary & tertiary
Secondary and Tertiary Collections
- 01
What it is.
Accounts that have already been through one or more collection agencies without resolving. By the time a file reaches this stage it usually carries stale contact data, a history of prior attempts, and a consumer who has heard from several companies already.
- 02
What the law allows.
Nothing about a later placement lowers the standard. The validation notice obligation runs again for us, the frequency limits reset against our own contacts rather than the prior agency’s, and any dispute or cease-contact instruction in the file’s history stays in force.
15 U.S.C. § 1692g(a) · 12 C.F.R. §§ 1006.34, 1006.14(b)(2)(i) - 03
How we work inside it.
We read the history before we make a contact. Prior disputes, prior cease-contact requests, prior attorney representation and prior payment arrangements are loaded and honoured as ours. Contact data is re-verified rather than reused, because a number that failed for the last agency is usually the wrong number, not an unresponsive consumer.
15 U.S.C. §§ 1692c(a)(2), (c) · 12 C.F.R. § 1006.6(c) - 04
Why we do it.
A file that has failed twice is usually a data problem or a communication problem, not an unwilling consumer. Fixing the data and changing the channel is what recovers these accounts, and it is also what stops the fourth wrong-party call.
01 Compliance
Compliance Controls
Prior disputes, cease-contact instructions and attorney representation loaded and honoured
Validation notice issued on our placement, independent of prior agencies
Contact frequency measured against our own attempts, inside the seven-in-seven limit
Contact data re-verified before dialing, to avoid wrong-party contact
Contact only 8:00 a.m. to 9:00 p.m. in the consumer’s own time zone
Statute-of-limitations status recalculated on receipt
Balance reconciled to client data, including all prior payments credited
Settlement authority limited to the client’s standing parameters
Consumers select their own plan, date and method in the portal
Calls recorded, monitored and scored against approved scripts
Agents trained to documented competency standards before taking accounts
State-specific limitation periods and disclosure requirements applied
The framework behind these controls, and our licensing and bonding, are on our Compliance page →
02 Limits
What We Never Do
Restart contact on a consumer who previously asked us or a prior agency to stop
Ignore a dispute recorded earlier in the account history
Reuse a phone number already known to reach the wrong person
Quote a balance that omits payments made to a prior agency
Present a later placement as a new or more serious legal posture
What a consumer can ask us to do — including disputing an account — is on Consumer Rights →
Locating the right person first
Most of the work on a later placement is confirming who and where the consumer is before anyone is contacted. The statutory limits on that are set out on our Location Information and Employment Verification pages.