Warehousing management
Warehousing Management
- 01
What it is.
Holding and monitoring accounts that active recovery has not resolved, at a reduced servicing rate, so a client does not have to write them off while they still have value.
- 02
What the law allows.
A warehoused account is still a consumer’s account. Retention is bounded by the client agreement and applicable law, monitoring is limited to permissible purposes, and any cease-contact instruction or dispute on the file remains in force for the entire time it is held.
15 U.S.C. § 1681b(a)(3) · § 1692c(c) · GLBA · 16 C.F.R. Part 314 - 03
How we work inside it.
Accounts are monitored for changes that indicate renewed ability to pay, and re-scored when something changes. Active recovery restarts only when there is a documented reason and the client authorizes it — and never on an account whose limitation period has run, or where the consumer has asked us to stop.
12 C.F.R. § 1006.26(b) · 15 U.S.C. § 1692c(c) - 04
Why we do it.
Closing an account the day active collection stops throws away recovery that would have arrived later, and re-placing it from scratch costs more than holding it. Holding it quietly, and only acting when something actually changes, is cheaper for the client and quieter for the consumer.
01 Compliance
Compliance Controls
Cease-contact instructions and disputes remain in force for the entire holding period
No contact attempts while an account is warehoused, absent client-authorized reactivation
Monitoring limited to permissible purposes and permitted data sources
Statute-of-limitations status recalculated continuously; expiry blocks reactivation for suit
Reactivation requires a documented trigger and written client authorization
On reactivation, a fresh validation notice is issued before collection proceeds
Retention bounded by the client agreement and applicable law; destruction on schedule
Data held encrypted, with role-based access and logged access
Accounts returned or purged on client instruction
State-specific retention and limitation requirements applied
The framework behind these controls, and our licensing and bonding, are on our Compliance page →
02 Limits
What We Never Do
Contact a consumer on a warehoused account without authorized reactivation
Reactivate an account whose limitation period has expired for the purpose of suit
Reactivate an account where the consumer has instructed us to cease contact
Pull or monitor consumer report data without a permissible purpose
Hold data beyond the retention period the client agreement allows
What a consumer can ask us to do — including disputing an account — is on Consumer Rights →
What a warehoused account is not
Warehousing is not silent collection. Nothing is sent, dialed or texted while an account is held. If a client wants activity, the account is reactivated deliberately and moves back into post charge-off recovery with a fresh validation notice, exactly as a new placement would.