This dated narrative contains pending corrections. Read the notes, then expand the original text.
S_AZ PASS-07 — Arizona collection communications, validation and disputes
The researched gateway has two separate layers: federal coverage depends on the debt and collector predicates, while Arizona’s collection-agency provisions have their own definitions, exemptions and conduct requirements. A state licensing exemption does not establish a federal exemption. Conversely, federal coverage does not establish Arizona licensing status. This pass makes no actual actor-status determination. C001–C017.
For a covered Arizona collection agency, the posted rules add meaningful information and investigation duties: specified information must be available within five days of initial communication; specified records must be accessible, with copies supplied without charge on request; and the agency must provide copies of its evidence and investigate the specified non-liability claims in the sequence prescribed by R20-4-1521. Those requirements must be considered separately from the federal pause triggered by a timely written dispute. C025–C028, C074–C084. apps.azsos.gov+1
The federal rules distinguish a communication from an attempt, a call-frequency presumption from permission, an oral dispute from the written-dispute pause, and ordinary electronic contact from electronic delivery of disclosures requiring E-SIGN compliance. Properly sending a qualifying verification response can end the federal verification pause; the consumer’s later reading of it is not a universal prerequisite. Other applicable restrictions, including Arizona’s investigation requirement, remain separate. C049–C063, C074–C086. Consumer Financial Protection Bureau+3
Scope, access and evidence conventions
- Actual research access: October 27, 2026 Pacific, later than the requested October 22 baseline. Individual source-opening times are unknown; a session clock is not an opening timestamp.
- Fresh research: The legal bodies identified below were opened for this pass. P02–P06 outputs are not legal or factual premises here.
- Important holds: Exhaustive reconciliation of Arizona Register changes after Supplement 25-4; authoritative reconciliation of Arizona identification rules with federal limited-content messages; actual actor, debt-purpose, default, contract, consent, delivery and territorial facts.
- Source hierarchy: Statutes and operative regulations control their respective questions. Official interpretations explain Regulation F. Published opinions are used within their holdings and procedural posture. Indexes establish only the bounded version checks described. Guidance does not establish liability or permission.
- Identifiers: In cross-references, S### means S_AZ-P07-S###, and C### means S_AZ-P07-C###. Every source and claim receives its full identifier in its register.
- Confidence: H = directly read text supports the stated, conditional proposition. HR = high confidence in the posted Arizona rule text, with the later-Register currentness hold. L = bounded published holding, without complete subsequent-history certification. P/Hold = the identified question remains partly or wholly unresolved.
- All PDF indexes below are zero based. HTML sources have no PDF index.
This is a focused component contribution. It is not independent review, statewide completion, an actual consumer/provider permission, or parent/A066/A097/A098 acceptance.
1. Complete source register
All access entries below refer to October 27, 2026 Pacific. Multiple sections of a compilation, and an agency’s alternative presentation of the same regulation, are not independent corroboration.
1.1 Arizona operative text and version checks
| Source ID |
Issuer, document and direct literal HTTPS URL |
Actual body read and exact location |
Version, effect, status and limitations |
| S_AZ-P07-S001 |
Arizona Legislature, A.R.S. Title 32. https://www.azleg.gov/ars/32/01001.htm; https://www.azleg.gov/ars/32/01004.htm; https://www.azleg.gov/ars/32/01051.htm; https://www.azleg.gov/ars/32/01055.htm; compilation notice: https://www.azleg.gov/arsDetail/?title=32 |
Fresh primary body. Definitions in §32-1001; all §32-1004 exemption text; §32-1051 conduct paragraphs; §32-1055, with reliance limited here to relevant actor/conduct/nexus clauses. Compilation disclaimer read. |
Legislature’s posted compilation, subject to its drafting/January-following-session disclaimer. Selected-section amendment checks below reduce, but do not eliminate, currentness limits. No actual license finding. Definitions+4 |
| S_AZ-P07-S002 |
Arizona Secretary of State/DIFI, 20 A.A.C. 4. https://apps.azsos.gov/public_services/Title_20/20-04.pdf |
Fresh operative portions. R20-4-1501, printed p.38/PDF39; R20-4-1507–1509, p.40/PDF41; R20-4-1510–1514, p.41/PDF42; R20-4-1515–1516 and R20-4-1520(A)–(B), p.42/PDF43; R20-4-1521, p.43/PDF44. Related historical notes read. |
Supplement 25-4, posted December 31, 2025. Not a claim that the entire 52-page chapter was substantively reviewed. Post-supplement Register reconciliation remains held under S034. No claim of successful visual inspection from unavailable screenshot output. apps.azsos.gov+1 |
| S_AZ-P07-S003 |
Arizona SOS/DIFI, final rulemaking, R23-162, 29 A.A.R. 1961–1968. https://apps.azsos.gov/public_services/register/2023/35/contents.pdf |
Fresh final-adoption portions. Item 3 and rationale, printed pp.1961–1962/PDF46–47; material definitions on p.1964/PDF49; relevant conduct rules pp.1966–1968/PDF51–53. |
Published September 1, 2023; stated effective date October 2, 2023. Current Code supplies clean operative wording where adoption extraction mixes deleted and added text. Entire 75-page Register issue not claimed read. apps.azsos.gov+1 |
| S_AZ-P07-S004 |
Arizona Legislature, Laws 2022, ch.59, HB2612. https://www.azleg.gov/legtext/55leg/2r/laws/0059.htm |
Fresh enacted portions: §51, amending §32-1004; §53, amending/renumbering §32-1051; approval/filed notation. |
Approved/filed March 24, 2022. General effective date established through S005–S006 as September 24, 2022. Approval is not the commencement date. Other parts of this large enactment are not this pass’s findings. H Ver of HB2612+2 |
| S_AZ-P07-S005 |
Arizona Legislative Council, 2022 Table of Sections Affected. https://www.azleg.gov/alisPDFs/council/TOSA_55th_2nd_Regular.pdf |
Fresh official index body: legend and printed p.18/PDF17, entries for §§32-1004 and 32-1051, ch.59 §§51 and 53, marked general-effective. |
September 28, 2022 version; chapters 1–388. Index corroborates amendment identification, not operative conduct wording. azleg.gov+1 |
| S_AZ-P07-S006 |
Arizona Legislature, General Effective Dates. https://www.azleg.gov/general-effective-dates/ |
Fresh official date table: 2022 regular-session row. |
Establishes September 24, 2022 general effective date used with S004–S005. Other displayed years are not substitute amendment histories. azleg.gov |
| S_AZ-P07-S007 |
Arizona Legislative Council, 2023 TOSA. https://www.azleg.gov/alisPDFs/council/TOSA_56th_1st_Regular.pdf |
Fresh index: sorted Title 32 range, printed p.8/PDF7. |
December 19, 2023 version, chapters 1–205. No entry for the four selected P07 statutory sections in that range. This is a bounded index check, not a finding about all collection law. azleg.gov |
| S_AZ-P07-S008 |
Arizona Legislative Council, 2024 TOSA. https://www.azleg.gov/alisPDFs/council/TOSA_56th_2nd_Regular.pdf |
Fresh index: Title 32 range, printed p.10/PDF9. |
No listed amendment to the four selected sections in the inspected range. Header publication date not established; not invented. azleg.gov |
| S_AZ-P07-S009 |
Arizona Legislative Council, 2024 election TOSA. https://www.azleg.gov/alisPDFs/council/TOSA_2024_election.pdf |
Fresh entire two-page index body, PDF0–1. |
No Title 32 entry found in this index. Index is not the enacted initiative text and supplies no broader initiative-validity conclusion. azleg.gov+1 |
| S_AZ-P07-S010 |
Arizona Legislative Council, 2025 TOSA. https://www.azleg.gov/alisPDFs/council/TOSA_57th_1st_Regular.pdf |
Fresh index: sorted Title 32 range, printed p.10/PDF9. |
No listed amendment to the four selected sections in the inspected range. No P02 renewal conclusion imported. azleg.gov |
| S_AZ-P07-S011 |
Arizona Legislative Council, 2026 TOSA. https://www.azleg.gov/alisPDFs/council/TOSA_57th_2nd_Regular.pdf |
Fresh index: header and Title 32 range, printed p.11/PDF10. |
August 19, 2026 version, chapters 1–264. No entry for §§32-1001, 1004, 1051 or 1055 in the inspected range. Not a complete later-enactment certificate. azleg.gov+1 |
| S_AZ-P07-S012 |
Arizona Legislative Council, 2026 delayed effective dates. https://www.azleg.gov/alisPDFs/council/2026_Delayed_effective_dates.pdf |
Fresh material index portions, PDF0–1, including listed Title 32 January 1, 2027 changes. |
Selected P07 sections not listed there. Not all three pages claimed read; no future-effective change inferred from an unrelated entry. azleg.gov+1 |
1.2 Federal statutes, Regulation F and adoption materials
| Source ID |
Issuer, document and direct literal HTTPS URL |
Actual body read and exact location |
Version, effect, status and limitations |
| S_AZ-P07-S013 |
U.S. House OLRC, Title 15 compilation. https://uscode.house.gov/us/usc/119-124/t15/s1692a/; https://uscode.house.gov/us/usc/119-124/t15/s1692b/; https://uscode.house.gov/us/usc/119-124/t15/s1692d/; https://uscode.house.gov/us/usc/119-124/t15/s1692e/; https://uscode.house.gov/us/usc/119-124/t15/s1692f/; https://uscode.house.gov/us/usc/119-124/t15/s1692g/; https://uscode.house.gov/us/usc/119-124/t15/s1692k/; https://uscode.house.gov/us/usc/119-124/t15/s1692n/; https://uscode.house.gov/us/usc/119-124/t15/s7001/; https://uscode.house.gov/us/usc/119-124/t15/s1681a/; https://uscode.house.gov/us/usc/119-124/t15/s1681b/ |
Fresh primary bodies: §§1692a–b, d–g, n; §1692k(c) for the narrow electronic-procedure defense cross-reference; §7001(a)–(c) and relevant related provisions; §1681a(f), (x)(3), and §1681b(a)(3). Earlier §7001 reading at https://uscode.house.gov/us/usc/119-121/t15/s7001/ was followed by the newer compilation check. |
Current pages state laws effective through P.L.119-124, October 15, 2026. Full FCRA, remedies, damages and limitation regimes are not analyzed merely because adjacent text was returned. §1692c’s failed OLRC route is recorded under S014. uscode.house.gov+4 |
| S_AZ-P07-S014 |
GovInfo, 15 U.S.C. §1692c. https://www.govinfo.gov/link/uscode/15/1692c |
Fresh full §1692c(a)–(d), printed p.1636/PDF0. |
Successful official alternate after https://uscode.house.gov/us/usc/119-124/t15/s1692c/ returned an internal retrieval error. GovInfo’s dynamic link did not establish its edition year; text was compared with current Regulation F and S015. A separate GovInfo definition route, https://www.govinfo.gov/link/uscode/15/1692a, yielded no readable body/then a 400 response; §1692a was resolved through S013. govinfo.gov |
| S_AZ-P07-S015 |
FTC, FDCPA text reproduction. https://www.ftc.gov/legal-library/browse/rules/fair-debt-collection-practices-act-text |
Fresh historical official reproduction: relevant definitions and communication/validation/state-law provisions. |
Page presents the Act as amended through the 2010 legislation and identifies its convenience function. Used as a cross-check, not a substitute for current Code. Federal Trade Commission |
| S_AZ-P07-S016 |
Office of the Federal Register/GPO, eCFR, 12 C.F.R. Part 1006. https://www.ecfr.gov/current/title-12/chapter-X/part-1006 |
Fresh operative bodies and material official commentary: §§1006.1, .2, .6, .10, .14, .18, .22, .30(a), .34, .38, .42 and .104; relevant Supplement I passages. |
Displayed Title 12 currency October 23, 2026. That is not a finding that Part 1006 was amended that day. eCFR is the official government editorial compilation, not the official annual legal edition. Model Form B-1’s image was not inspected; no actual form approved. ecfr.gov+3 |
| S_AZ-P07-S017 |
CFPB, interactive Regulation F and official interpretations. https://www.consumerfinance.gov/rules-policy/regulations/1006/2/; https://www.consumerfinance.gov/rules-policy/regulations/1006/6/; https://www.consumerfinance.gov/rules-policy/regulations/1006/10/; https://www.consumerfinance.gov/rules-policy/regulations/1006/14/; https://www.consumerfinance.gov/rules-policy/regulations/1006/18/; https://www.consumerfinance.gov/rules-policy/regulations/1006/22/; https://www.consumerfinance.gov/rules-policy/regulations/1006/30/; https://www.consumerfinance.gov/rules-policy/regulations/1006/34/; https://www.consumerfinance.gov/rules-policy/regulations/1006/38/; https://www.consumerfinance.gov/rules-policy/regulations/1006/42/ |
Fresh material bodies/comments, particularly identity, communication procedures, call counting, itemization, receipt, disputes and delivery. These are alternative presentations of S016’s authority. |
Pages label themselves current regulation. The §38 mirror retains an incorrect internal comment reference to “38–1.ii”; S020 and eCFR establish the corrected “iii” reference for electronic consumer submissions. No claim that the mirror is error-free. Consumer Financial Protection Bureau+5 |
| S_AZ-P07-S018 |
CFPB, 2020 final Regulation F rule, 85 F.R. 76734. https://www.federalregister.gov/documents/2020/11/30/2020-24463/debt-collection-practices-regulation-f |
Fresh DATES and material introductory/effective-date passages. |
Published November 30, 2020; effective November 30, 2021. Entire lengthy preamble not claimed read. federalregister.gov |
| S_AZ-P07-S019 |
CFPB, validation/disclosure final rule, 86 F.R. 5766. https://www.federalregister.gov/documents/2021/01/19/2020-28422/debt-collection-practices-regulation-f |
Fresh DATES and material introductory/effective-date passages. Operative text read through S016–S017. |
Published January 19, 2021; effective November 30, 2021. Publication and commencement kept separate. federalregister.gov |
| S_AZ-P07-S020 |
CFPB, Regulation F corrections, 87 F.R. 65668–65670. https://www.federalregister.gov/documents/2022/11/01/2022-23559/debt-collection-practices-regulation-f-corrections |
Fresh material correction body, including comments 30(a)(1)-3 and 38-2/38-3 and the corrected electronic-submission cross-reference. |
Effective November 1, 2022. Technical correction, not a newly created 30-day collector-response period. federalregister.gov |
| S_AZ-P07-S021 |
CFPB, Agency Contact Information rule. https://www.federalregister.gov/documents/2023/03/20/2023-05216/agency-contact-information |
Fresh DATES and Part 1006 amendment instructions 8–10, printed p.16538 in the Federal Register pagination. |
Effective April 19, 2023. Relevant changes concern agency contact/organizational information. The rule’s later mandatory dates for other regulations’ forms are not Regulation F dispute-clock changes. federalregister.gov+1 |
| S_AZ-P07-S022 |
OLRC, Title 12 cross-references. https://uscode.house.gov/us/usc/119-124/t12/s5481/; https://uscode.house.gov/us/usc/119-124/t12/s5519/ |
Fresh necessary portions: §5481(5), (7), (15)(A)(i); §5519(a), relevant (b), (c), (f). |
Same P.L.119-124 currency. Supports the consumer-financial-product subset and Regulation F’s auto-dealer boundary, not a complete sector opinion. uscode.house.gov+1 |
| S_AZ-P07-S023 |
GovInfo, 5 U.S.C. §6103. https://www.govinfo.gov/link/uscode/5/6103 |
Fresh holiday text: §6103(a), associated portions and source notes, printed pp.791–793/PDF0–2. |
Official alternate after https://uscode.house.gov/us/usc/119-124/t5/s6103/ was inaccessible. Dynamic-link edition year unestablished; Juneteenth amendment appears. Used for the expressly incorporated holiday list, not general court-calendar rules. govinfo.gov |
1.3 Published judicial opinions
| Source ID |
Court, opinion and direct literal HTTPS URL |
Actual body read / pinpoint |
Status and limits |
| S_AZ-P07-S024 |
U.S. Supreme Court, Henson v. Santander Consumer USA Inc. https://www.supremecourt.gov/opinions/16pdf/16-349_c07d.pdf |
Fresh entire majority, slip pp.1–11/PDF2–12; principal-purpose reservation at slip p.3/PDF4. |
June 12, 2017, unanimous published opinion. Own-account purchase holding does not decide the principal-purpose prong. supremecourt.gov |
| S_AZ-P07-S025 |
Ninth Circuit, McAdory v. M.N.S. & Associates, LLC. https://cdn.ca9.uscourts.gov/datastore/opinions/2020/03/09/18-35923.pdf |
Fresh majority portion, printed pp.3–17/PDF2–16; principal-purpose analysis especially pp.11–16. |
March 9, 2020, marked FOR PUBLICATION. Reversal/remand of dismissal; allegations and classification holding are not final vicarious-liability findings. Bea dissent identified, not used as majority law. cdn.ca9.uscourts.gov |
| S_AZ-P07-S026 |
U.S. Supreme Court/GovInfo, Heintz v. Jenkins, 514 U.S. 291. https://www.govinfo.gov/content/pkg/USREPORTS-514/pdf/USREPORTS-514-291.pdf |
Fresh majority, printed pp.292–299/PDF1–8. |
April 18, 1995, unanimous. Regular litigation-related consumer-debt collection can meet FDCPA coverage; not a ruling that every lawyer or every litigation act violates the Act. govinfo.gov |
| S_AZ-P07-S027 |
U.S. Supreme Court, Obduskey v. McCarthy & Holthus LLP. https://www.supremecourt.gov/opinions/18pdf/17-1307_7lho.pdf |
Fresh entire majority, slip pp.1–14/PDF3–16; limitations/reservations at slip pp.12–14. |
March 20, 2019, unanimous majority. Colorado nonjudicial-security-enforcement posture. Separate concurrence not relied on; full foreclosure/repossessions deferred. supremecourt.gov |
| S_AZ-P07-S028 |
Ninth Circuit, Hernandez v. Williams, Zinman & Parham PC. https://cdn.ca9.uscourts.gov/datastore/opinions/2016/07/20/14-15672.pdf |
Fresh material majority: pp.3–9/PDF2–8 and pp.20–26/PDF19–25; holding pp.25–26/PDF24–25. |
July 20, 2016, FOR PUBLICATION. Each successive collector’s initial covered communication matters. Not every intervening page claimed read; actor status was conceded in the case. cdn.ca9.uscourts.gov |
| S_AZ-P07-S029 |
Ninth Circuit opinion reproduced by Justia, Camacho v. Bridgeport Financial Inc., 430 F.3d 1078. https://law.justia.com/cases/federal/appellate-courts/F3/430/1078/505439/ |
Fresh primary-opinion reproduction: Background, Discussion, Conclusion and relevant footnotes, particularly footnote 4. |
December 12, 2005. Candidate official route https://cdn.ca9.uscourts.gov/datastore/opinions/2005/12/12/0417126.pdf failed; reproduction used after that failure. Host summaries/headnotes excluded. HTML; PDF index unavailable. Later treatment actually read in S031. law.justia.com |
| S_AZ-P07-S030 |
Ninth Circuit opinion reproduced by Justia, Clark v. Capital Credit & Collection Services, Inc., 460 F.3d 1162. https://law.justia.com/cases/federal/appellate-courts/F3/460/1162/580673/ |
Fresh material majority: §I, cease-contact waiver and verification discussion; verification paragraphs at rendered lines 134–143; §II/disposition. Relevant separate dissent read for distinction. |
August 24, 2006. Candidate official route https://cdn.ca9.uscourts.gov/datastore/opinions/2006/08/24/0435563.pdf failed. Reproduction, not host summary, relied on. HTML; reporter-page/PDF pairing not fabricated. law.justia.com |
| S_AZ-P07-S031 |
Ninth Circuit, Riggs v. Prober & Raphael. https://cdn.ca9.uscourts.gov/datastore/opinions/2012/06/08/10-17220.pdf |
Fresh entire 13-page opinion file. Majority Parts III–IV, printed pp.6534–6538/PDF8–12, supply the relevant later treatment of Camacho. |
June 8, 2012, FOR PUBLICATION. Historical notice decision; not approval of a notice under the later Regulation F requirements. cdn.ca9.uscourts.gov |
1.4 Guidance, failed routes and discovery-only materials
Additional retrieval limit: An eCFR link to E-SIGN produced an internal retrieval error without a usable destination in the returned result. Its exact failed destination is not invented here. The necessary §7001 body was then read at the literal OLRC URLs in S013.
2. Atomic claim and evidence matrices
These tables provide the substantive findings. Each row describes a conditional legal proposition, not an actual provider or consumer determination.
2.1 Debt, actor and territorial predicates
| Claim ID |
Actor / predicate |
Required classification, consequence or boundary |
Exact authority; exceptions and confidence |
| S_AZ-P07-C001 |
Natural person and asserted obligation |
Federal “debt” requires a transaction primarily for personal, family or household purposes; a judgment can remain within that definition. A natural-person borrower alone does not convert business debt into consumer debt. |
S013, §1692a(3), (5); S016–S017, §1006.2(d), (h). H; actual purpose held. |
| S_AZ-P07-C002 |
Collector’s message or contact effort |
Conveying debt information directly or indirectly is a communication. Regulation F also regulates attempts, including qualifying limited-content messages; an unsuccessful attempt need not be a communication. |
S013, §1692a(2); S016–S017, §1006.2(a), (c), (j). H. |
| S_AZ-P07-C003 |
Business using interstate instrumentalities or mail |
Test both principal-purpose collection and regular collection of debts owed another. The alternatives must be tested independently. |
S013, §1692a(6), opening definition; S016–S017, §1006.2(i)(1). H. |
| S_AZ-P07-C004 |
Original creditor collecting its own account |
Own-account collection does not satisfy the owed-another route merely because payment is demanded. Use of another name suggesting a third-party collector invokes an express inclusion; other applicable predicates still require testing. |
S013, §1692a(4), (6); S017, §1006.2(g), (i)(1). H; no blanket original-creditor clearance. |
| S_AZ-P07-C005 |
Creditor’s officer or employee |
The federal exclusion requires collection for that creditor in the creditor’s name. Independent contractors do not receive this exclusion merely by being called staff. |
S013, §1692a(6)(A); S017, §1006.2(i)(2)(i). H; employment/name facts held. |
| S_AZ-P07-C006 |
Affiliate collector |
Federal exclusion requires collection only for related/common-control entities and a principal business other than debt collection. Corporate affiliation alone is insufficient. |
S013, §1692a(6)(B); S017, §1006.2(i)(2)(ii). H. |
| S_AZ-P07-C007 |
Servicer or other person collecting another’s debt |
The exclusion applies only to the specified extent: incidental fiduciary/escrow activity, originated debt, debt not in default when obtained, or specified commercial-secured-party collection. Default acquisition alone does not decide every prong. |
S013, §1692a(6)(F)(i)–(iv); S017, §1006.2(i)(2)(vi); S024–S025. H; actual default and acquisition facts held. |
| S_AZ-P07-C008 |
Government personnel, process server, nonprofit counselor |
Exclusions are activity-specific: official duties; service of process; or bona fide nonprofit counseling receiving/distributing payments at consumers’ request. A title or nonprofit label alone is insufficient. |
S013, §1692a(6)(C)–(E); S017, §1006.2(i)(2)(iii)–(v). H. Separate bad-check-program statutory conditions remain held. |
| S_AZ-P07-C009 |
Buyer collecting purchased debt for itself |
Henson rejects coverage under the owed-another prong based solely on the debt’s defaulted status before purchase; it expressly leaves principal-purpose coverage undecided. |
S024, slip pp.1–3, 5–11/PDF2–4, 6–12. L. |
| S_AZ-P07-C010 |
Buyer whose principal purpose is collecting purchased debts through contractors |
Outsourcing does not itself remove principal-purpose coverage. McAdory found the pleaded business model sufficient and remanded; ultimate responsibility for particular misconduct was not finally resolved. |
S025, majority pp.11–17/PDF10–16. L. |
| S_AZ-P07-C011 |
Attorney regularly collecting consumer debts |
Litigation-related collection can fall within the FDCPA. There is no general federal attorney exemption. |
S026, 514 U.S. pp.292–299/PDF1–8; S013, §1692a amendment notes. L/H; particular conduct still tested separately. |
| S_AZ-P07-C012 |
Person engaged only in specified security-interest enforcement |
Obduskey applies the limited-purpose definition for §1692f(6) to its nonjudicial-foreclosure posture. Ordinary money demands or other collection business require separate analysis. |
S027, slip pp.6–14/PDF8–16; S013, §1692a(6), security-interest sentence. L; foreclosure/repo regime deferred. |
| S_AZ-P07-C013 |
Arizona claim/agency/debtor |
Arizona’s general claim and rule debt definitions do not contain the federal personal/family/household limitation. State contact includes attempted contact; agency status derives from state definitions. |
S001, §32-1001(1), (2), (6); S002, R20-4-1501, p.38/PDF39. H/HR. |
| S_AZ-P07-C014 |
Arizona exempt-category actor |
§32-1004’s exemptions are conditioned on regular-course activity and retain specified statutory duties. Attorney, employee, institutional, affiliate and billing-service predicates differ. The entire agency-rule article is not automatically imposed on every exempt actor. |
S001, §32-1004(A), especially (1)–(3), (7), (13)–(14), (B)–(D). Billing exception requires all five conditions; institutional cross-reference eligibility remains P06 work. H; actual exemption held. |
| S_AZ-P07-C015 |
Remote collector contacting an Arizona debtor |
Federal mail/interstate predicates and Arizona territorial applicability are distinct. Arizona text contemplates an agency without an Arizona office, so office absence alone cannot resolve coverage. The complete remote-contact jurisdiction test was not established. |
S001, §32-1055(A), (B), (D)(2); S013, §1692a(6). P/Hold on actual nexus and choice of law. |
| S_AZ-P07-C016 |
Concurrent state and federal protections |
The FDCPA preserves state protections except to the extent of inconsistency; greater consumer protection is not inconsistent merely because it is greater. |
S013, §1692n; S016, §1006.104. H; no complete preemption/choice-of-law opinion. |
| S_AZ-P07-C017 |
Regulation F actor and covered product |
Regulation F’s coverage clause includes its statutory auto-dealer boundary. Some validation fields apply only to debt related to a consumer financial product/service. Neither qualification creates a universal FDCPA exemption. |
S016, §1006.1(c), §1006.34(c)(2)(iii), (c)(3)(iv); S022, §§5481, 5519. H; special-sector eligibility held. |
2.2 Arizona communication and information requirements
Here, “covered Arizona agency” means an actor to which the identified agency rule applies after the state predicates and exemptions are resolved. It does not mean every federal debt collector.
| Claim ID |
Actor / predicate |
Required act, trigger or consequence |
Exact authority; exceptions and confidence |
| S_AZ-P07-C018 |
Covered Arizona agency and its personnel |
Agency communications must identify the agency’s collection role; personnel must indicate their collector role and cannot misrepresent their position. |
S002, R20-4-1507(1)–(4), p.40/PDF41; R20-4-1520(A)–(B), p.42/PDF43. HR; federal LCM reconciliation held. |
| S_AZ-P07-C019 |
Covered agency discussing legal consequences |
No false law/process/arrest representations, nonexistent filed suits, insincere suit/referral threats, false waiver-by-silence statements or misrepresented remedies. |
S002, R20-4-1508; -1509(B)–(D); -1510, pp.40–41/PDF41–42. HR; actual litigation procedure deferred. |
| S_AZ-P07-C020 |
Agency collection directed at any person |
Oppressive harassment, humiliation, criminal insinuations and obscene/abusive collection language are prohibited. |
S002, R20-4-1511(A)–(D), p.41/PDF42. HR. |
| S_AZ-P07-C021 |
Agency telephone contact |
Calls must occur at reasonable hours; workplace contact follows a failed reasonable residence-contact attempt under this state rule. |
S002, R20-4-1512(A), p.41/PDF42. HR. This does not override C035’s federal workplace restriction. |
| S_AZ-P07-C022 |
Agency contacting friends, relatives, neighbors or employers |
No prohibited debt disclosure, pressure request or request that a nonobligated third party pay. The rule separately preserves lawful postjudgment writ service. |
S002, R20-4-1512(B)–(C), p.41/PDF42. HR; writ procedures not analyzed. |
| S_AZ-P07-C023 |
Debtor tells agency of counsel and requests communication through counsel |
Agency must stop direct and indirect debtor contact; the stated later-contact route is learning from the named lawyer that the lawyer does not represent the debtor. |
S002, R20-4-1513(A), p.41/PDF42. HR. Do not import the federal reasonable-nonresponse exception into this text. |
| S_AZ-P07-C024 |
Debtor gives written refusal-to-pay or cease notice |
Agency stops contact subject to the state rule’s termination and customary-specified-remedy notices. A mailed notice becomes effective on agency receipt. |
S002, R20-4-1513(B)–(D), p.41/PDF42. HR. State exceptions must not be replaced wholesale with the federal list. |
| S_AZ-P07-C025 |
Agency’s initial debtor communication |
Within five days, obtain and be able to provide creditor identity, creation time/place, exchanged goods/services/value, and placement date. |
S002, R20-4-1514(A)(1)–(4), p.41/PDF42. HR. This is not worded as the federal five-day notice. |
| S_AZ-P07-C026 |
Debtor seeks those specified records |
Provide access; on request, provide without charge copies from agency records containing the listed information. |
S002, R20-4-1514(B)–(C), p.41/PDF42. HR; limited to the identified records, not universal discovery. |
| S_AZ-P07-C027 |
Debtor or debtor’s attorney requests evidence |
Agency must supply copies of its evidence of the debt. |
S002, R20-4-1521, opening sentence, p.43/PDF44. HR. Text does not prescribe a universal original contract or notarized affidavit. |
| S_AZ-P07-C028 |
Agency has supplied evidence and receives a specified non-liability claim |
Before continuing collection, investigate claimed misidentification, payment, bankruptcy discharge, or another reasonable claim that the debt is not owed. |
S002, R20-4-1521(1)–(4), p.43/PDF44. HR. No express writing/30-day prerequisite appears here; do not invent an immediate universal pause outside the stated sequence. |
| S_AZ-P07-C029 |
Actor subject to retained §32-1051(3) duty |
Collection/attorney/court/expense charges require the statutory legal-chargeability or judicial-determination predicate. |
S001, §32-1051(3), first sentence; §32-1004(A). H. Express attorney carveout in that sentence; no fee amount or actual charge approved. |
| S_AZ-P07-C030 |
Licensee or actor subject to applicable retained statutory conduct clauses |
Unfair collection and specified misleading notices, false legal-department claims and state-vouching representations are restricted. Attorney exceptions in paragraphs (3)–(5) must be respected individually. |
S001, §32-1051(3), second sentence, (4)(a)–(e), (5), (6); §32-1004(A). H; not a blanket attorney immunity or coverage finding. |
| S_AZ-P07-C031 |
Covered agency demanding an added fee |
R20-4-1509(A) prohibits threatening or attempting charges the debtor is not obliged to pay under the contract with the agency’s creditor client. |
S002, R20-4-1509(A), p.40/PDF41. HR. Federal agreement-or-law language does not itself resolve a disputed state charge route. |
| S_AZ-P07-C032 |
Actor using claim-sale publicity to coerce payment |
Coercive advertising/threatened advertising of claims for sale is prohibited, subject to the stated assignee-for-creditors/court-order exceptions. |
S001, §32-1055(C), as retained by §32-1004(A). H; actual exception facts held. |
2.3 Federal contact, conduct and reporting
| Claim ID |
Actor / predicate |
Required act, trigger or consequence |
Exact authority; exceptions and confidence |
| S_AZ-P07-C033 |
Covered collector communicating or attempting contact |
Actual knowledge of inconvenience matters. Absent contrary knowledge, the ordinary time assumption is after 8 a.m. and before 9 p.m. at the consumer’s location. |
S014, §1692c(a)(1); S016–S017, §1006.6(b)(1), commentary. H; not permission for every daytime contact. |
| S_AZ-P07-C034 |
Email/text or uncertain location |
Electronic-contact time is assessed when sent. Where available information creates conflicting time-zone possibilities, the commentary requires a time convenient under all implicated locations. |
S017, comments 6(b)(1)-1 through -4. H; actual location/knowledge held. |
| S_AZ-P07-C035 |
Collector knows or has reason to know employer prohibits the contact |
Workplace communication/attempt is prohibited, subject to the specific direct-consent/court exceptions. |
S014, §1692c(a)(3); S017, §1006.6(b)(3)–(4), comment 6(b)(3)-1. H. Failed home contact does not cure this. |
| S_AZ-P07-C036 |
Collector knows representation concerning the debt and knows/can readily ascertain counsel’s name/address |
Direct debtor contact is restricted; federal exceptions include counsel’s consent or failure to respond within a reasonable period. |
S014, §1692c(a)(2); S017, §1006.6(b)(2). H; “reasonable” is not a fixed number established here; C023 remains separate. |
| S_AZ-P07-C037 |
Collector invokes consent or court permission |
Consent must be given directly to this collector under the prescribed conditions; creditor/prior-collector consent does not automatically suffice. Known inconvenient contact cannot be prolonged by asking consent to continue it. |
S017, §1006.6(b)(4), comments 6(b)(4)(i)-1–2. H; actual consent/order held. |
| S_AZ-P07-C038 |
Communication with someone other than the consumer |
Only listed recipients and specific exceptions qualify. Spouse/minor-parent/guardian/estate-representative treatment for this section does not itself impose debt liability on them. |
S014, §1692c(b), (d); S017, §1006.6(a), (d)(1)–(2). H. Location, direct consent, court and necessary postjudgment exceptions remain bounded. |
| S_AZ-P07-C039 |
Collector seeks location information |
Identify the individual caller; identify employer only if asked; do not reveal the debt. Generally contact the person once, subject to the specified request/correction exceptions; counsel knowledge limits this route. |
S013, §§1692a(7), 1692b(1)–(6); S017, §1006.10(a)–(f). H. |
| S_AZ-P07-C040 |
Consumer sends written refusal/cease notice, including accepted electronic writing |
Receipt triggers the communication/attempt prohibition, subject to termination, ordinarily invoked specified remedies, and intended specified-remedy notices. |
S014, §1692c(c); S017, §1006.6(c), comment 6(c)(1)-1–2. H; no automatic debt cancellation. |
| S_AZ-P07-C041 |
Consumer initiates a response after a restriction |
A limited response can be permissible within the initiating request. It does not generally authorize future unrelated contacts or erase known representation. Clark requires a bounded waiver analysis. |
S017, comments 6(b)(1), 6(b)(2); S030, majority §I, cease-contact discussion. H/L; scope and recipient facts matter. |
| S_AZ-P07-C042 |
Collector’s cumulative conduct toward any person |
Harassment/oppression/abuse prohibitions apply beyond numerical telephone presumptions, including threats of violence and obscene or abusive language. |
S013, §1692d and (1)–(6); S017, §1006.14(a), (c)–(g). H. |
| S_AZ-P07-C043 |
Collector represents amount, identity, status or consequences |
False amount/status, government or attorney identity, simulated process, and threats of action unlawful or not intended are prohibited. A transfer cannot falsely be said to eliminate defenses. |
S013, §1692e(1)–(7), (9)–(10), (13), (16); S017, §1006.18(a)–(d). H; truth and legal entitlement are actual-fact questions. |
| S_AZ-P07-C044 |
Initial and later covered communications |
Initial disclosure identifies debt collection and intended use of information; initial oral contact requires the prescribed first-written disclosure too. Later communications identify the collector. Formal pleadings have a narrow disclosure exception. |
S013, §1692e(11); S017, §1006.18(e). H; not a blanket pleading exemption from all law. |
| S_AZ-P07-C045 |
Collector demands interest, fee or incidental charge |
Amount must be expressly authorized by the agreement creating the debt or permitted by law. Listing it in a notice does not authorize it. |
S013, §1692f(1); S017, §1006.22(a). H; agreement/law and Arizona C029/C031 remain unproved. |
| S_AZ-P07-C046 |
Collector accepts or uses postdated payment instrument |
A date more than five days ahead invokes the specified advance-deposit notice; Regulation F counts that notice’s 3–10-day interval excluding Saturdays, Sundays and §6103(a) holidays. Early deposit and criminal-prosecution solicitation are separately restricted. |
S013, §1692f(2)–(4); S017, §1006.22(b)(1)–(3); S023. H; no instrument or payment modeled. |
| S_AZ-P07-C047 |
Collector communicates credit information it knows or should know is false |
Failure to communicate that a known disputed debt is disputed can violate the provision. The dispute need not satisfy the written-validation-pause predicate to matter here. |
S013, §1692e(8); S017, §1006.18(c)(2); S029, Discussion. H/L; full FCRA obligations deferred. |
| S_AZ-P07-C048 |
Collector furnishes to a consumer reporting agency |
First speak with the consumer or send a debt communication and reasonably wait/monitor for undeliverability. The commentary treats 14 consecutive days as reasonable, not a universal statutory deadline. A specified check-writing-specialty exception exists. |
S017, §1006.30(a)(1)–(2), comments 30(a)(1)-1–3; S013, §1681a(f), (x)(3). H; no furnishing clearance. |
2.4 Calls, voicemail and electronic channels
| Claim ID |
Actor / predicate |
Required act, trigger or consequence |
Exact authority; exceptions and confidence |
| S_AZ-P07-C049 |
Collector places calls to a person concerning a particular debt |
More than seven counted calls in seven consecutive days, or a call within the post-conversation period, creates a rebuttable violation presumption. Staying below both creates only the specified rebuttable frequency presumption. |
S017, §1006.14(b)(1)–(2), associated comments. H; not a universal cap or safe harbor. |
| S_AZ-P07-C050 |
Telephone conversation about the debt occurs |
Conversation date is day one of the seven-consecutive-day period. A consumer-initiated conversation can trigger it even though it is not an outgoing placed call. |
S017, §1006.14(b)(2)(i)(B), comments on telephone conversations and counting. H. |
| S_AZ-P07-C051 |
Particular outgoing call is classified |
Busy/out-of-service unconnected calls are excluded; ringing unanswered and voicemail connections count. Calls to specified professional recipients are excluded from these frequencies. |
S017, §1006.14(b)(3)(ii)–(iii), comments 14(b)(3)(ii)-1–2. H; exclusions do not erase other restrictions. |
| S_AZ-P07-C052 |
Person directly consents to additional calls about a debt |
Frequency exclusion lasts no more than seven consecutive days, counting consent day as day one, and can end sooner through narrower consent, revocation or the next conversation. |
S017, §1006.14(b)(3)(i), comments 1–3. H; cannot waive C033/C035/C061 by implication. |
| S_AZ-P07-C053 |
One person has several debts |
Count by person and particular debt. A call/conversation concerning several debts can count for each; unconnected-to-content or general attempts must be allocated consistently with commentary, not ignored. |
S017, §1006.14(b)(2), (4), associated multiple-debt comments. H; limited student-loan grouping is a separate boundary. |
| S_AZ-P07-C054 |
Collector leaves a proposed limited-content message |
It must be a voicemail for the consumer with a non-collection-indicating business name, reply request, natural-person contact name and return number. Only the listed optional salutation/time/callback/representative content may be added. |
S017, §1006.2(j)(1)–(2). H; email/text are not this voicemail category. |
| S_AZ-P07-C055 |
LCM reaches a known third party or contains extra collection detail |
A knowingly third-party message or excess content does not qualify. A federal LCM remains an attempt and does not resolve Arizona’s role-identification rules. |
S017, comments 2(j)-1–3; S002, R20-4-1507, -1520(B). H federally; Arizona harmonization Hold. |
| S_AZ-P07-C056 |
Collector relies on email/text third-party-disclosure procedures |
Reasonably confirm and document the specified address/number route and avoid a destination known to have caused prohibited disclosure. These are procedures relevant to a bona fide-error defense, not blanket authorization or automatic immunity. |
S017, §1006.6(d)(3); S013, §1692k(c). H; intent, procedures and evidentiary burden remain fact dependent. |
| S_AZ-P07-C057 |
Email route rests on consumer or prior collector |
Consumer debt-related use/no opt-out or direct unwithdrawn consent can supply a route. Prior-collector route additionally requires qualifying acquisition and actual use by the immediately prior collector, without opt-out. |
S017, §1006.6(d)(4)(i), (iii), comments. H; C056 and disclosure-delivery duties remain separate. |
| S_AZ-P07-C058 |
Email route rests on creditor transfer notice |
Requires creditor acquisition/use, specified advance notice, at least 35 days to opt out, expiration without opt-out, and the qualifying public-domain/non-employer conditions. |
S017, §1006.6(d)(4)(ii)(A)–(E). H; an address transferred in a data file alone does not establish the route. |
| S_AZ-P07-C059 |
Text-message route |
Requires qualifying prior text use or direct consent, no withdrawal/opt-out, and the prescribed 60-day recent-text/consent or reassignment-confirmation condition. A voice call alone does not establish the prior-text route. |
S017, §1006.6(d)(5)(i)–(ii), comments. H; no database or number queried. |
| S_AZ-P07-C060 |
Electronic communication/attempt to an address or number |
Include a clear, conspicuous, reasonable and simple opt-out method. Do not impose a fee or demand unnecessary information beyond the preference and destination. |
S017, §1006.6(e), commentary. H. |
| S_AZ-P07-C061 |
Consumer requests no contact through a medium/address |
Oral requests can trigger the medium restriction. An address-specific opt-out applies to that collector’s use of that address across debts; narrow confirmation, consumer-initiated-response and legally required-medium exceptions remain. |
S017, §1006.14(h)(1)–(2), commentary. H; stopping one channel is not necessarily an all-channel cease notice. |
| S_AZ-P07-C062 |
Collector knows an email address is employer provided |
Use is generally prohibited except the specified consumer/prior-collector routes. Creditor-transfer procedures do not authorize known workplace email. |
S017, §1006.22(f)(3); §1006.6(d)(4)(i), (iii). H; actual knowledge/route held. |
| S_AZ-P07-C063 |
Social-media or postal collection contact |
Publicly visible social-media contact is restricted. Private messaging still faces other requirements. Postcards and collection-revealing envelope markings have separate prohibitions. |
S013, §1692f(7)–(8); S017, §1006.22(f)(1)–(2), (4). H; no TCPA/privacy/FCRA clearance. |
2.5 Initial validation, disputes, verification and resumption
| Claim ID |
Actor / predicate |
Trigger, required step, clock or consequence |
Exact authority; exceptions and confidence |
| S_AZ-P07-C064 |
Collector makes its initial covered communication |
Provide complete validation information in that communication or send the required notice within five days. Complete oral initial information is a regulatory route; payment before the follow-up notice becomes due is an exception. |
S013, §1692g(a); S017, §1006.34(a)(1)–(2). H. No universal “five business days” substitution established. |
| S_AZ-P07-C065 |
A new collector takes over the account |
Its own initial covered communication triggers its notice obligation; a predecessor’s notice is not a universal substitute. |
S028, pp.25–26/PDF24–25; S017, §1006.34(b)(2). L/H. |
| S_AZ-P07-C066 |
First contact is a formal pleading or specified mandatory noncollection notice |
Formal pleadings and the specified noncollection tax/financial-privacy/breach notices are excluded from the initial-communication trigger. |
S013, §1692g(d)–(e); S017, §1006.34(b)(2)(i)–(iii), commentary. H; no general litigation immunity. |
| S_AZ-P07-C067 |
Collector supplies validation information |
Required fields include collector/consumer information, dispute mailing address, account identifier, current creditor, amount information, rights and response prompts. Itemization-date creditor and CFPB-site fields have the consumer-financial-product qualification. |
S017, §1006.34(c)(1)–(4); S022. H; itemization-date creditor is not necessarily original creditor. |
| S_AZ-P07-C068 |
Collector selects an itemization reference |
Choose an ascertainable last-statement, charge-off, last-applied-payment, transaction or judgment date and use it consistently. A successor can choose another permitted reference. |
S017, §1006.34(b)(3)(i)–(v), comments 34(b)(3)-1–2. H; this selection does not determine limitation accrual. |
| S_AZ-P07-C069 |
Collector itemizes the balance |
Disclose the reference-date amount, subsequent interest/fees/payments/credits and current amount; required zero categories are not simply omitted. Itemization does not prove ownership or authorize an added charge. |
S017, §1006.34(c)(2)(vi)–(ix), commentary; C045. H; accounting truth remains unverified. |
| S_AZ-P07-C070 |
Validation information is provided |
Period begins when provided and ends 30 days after actual or assumed receipt. Assumed receipt may be at least five days later, excluding Saturdays, Sundays and §6103(a) holidays. |
S017, §1006.34(b)(5); S023. H; the exclusion applies to this receipt calculation, not every clock. |
| S_AZ-P07-C071 |
Actual receipt differs or original notice is undelivered |
Commentary permits the calculated assumed-receipt endpoint despite later learning a different actual receipt date. A replacement notice after nonreceipt/no other validation information requires an updated period. |
S017, comments 34(b)(5)-1–2. H; disputed endpoint litigation and actual delivery evidence held. |
| S_AZ-P07-C072 |
Consumer timely submits written request for original-creditor identity |
Upon receipt, collector must cease collection until it sends the name and address using the required delivery method. |
S013, §1692g(a)(5), (b); S017, §1006.38(c)(1), §1006.42. H; information obtained internally is not enough. |
| S_AZ-P07-C073 |
Original and current creditor are the same |
Collector may reasonably determine that identity, send a written/electronic statement of that fact and refer to previously supplied validation information. |
S017, §1006.38(c)(2). H; unsupported assertion or silence does not satisfy the alternative. |
| S_AZ-P07-C074 |
Consumer disputes orally |
Oral dispute is recognized for §1692g(a)(3) and can matter to disputed reporting, but does not by itself invoke the statutory written-dispute verification pause. |
S029, Discussion/Conclusion and fn.4; S013, §§1692g(a)(3)–(5), (b), 1692e(8). L/H; Arizona C028 may independently matter. |
| S_AZ-P07-C075 |
Historical notice implies, rather than expressly states, a writing condition |
Riggs distinguished Camacho and upheld the particular notice against the preserved theory. It does not approve any current notice or eliminate Regulation F’s fields. |
S031, Parts III.A–C, IV, pp.6534–6538/PDF8–12. L; historical version/posture limitation. |
| S_AZ-P07-C076 |
Collector receives a dispute submitted in writing within the validation period |
Stop collection of the debt or disputed portion until the qualifying verification/judgment response is sent. |
S013, §1692g(b); S017, §1006.38(d)(2)(i), §1006.42. H; submission/receipt and disputed portion require proof. |
| S_AZ-P07-C077 |
Consumer makes the required written submission |
Mail, response form, accepted electronic medium, courier or personal delivery can qualify. Consumer electronic writing is not conditioned on obtaining the consumer’s own E-SIGN §101(c) disclosure consent. |
S017, comments 38-1–2; S020 corrected reference; S013, §7001(a)–(b). H; collector must actually accept that electronic medium. |
| S_AZ-P07-C078 |
Timely written dispute remains unanswered |
The researched provisions do not establish a general 30-day collector-response deadline. The collection pause persists absent the qualifying response; silence does not cancel the debt. |
S013, §1692g(b); S017, §1006.38(d)(2). H, limited to these provisions. |
| S_AZ-P07-C079 |
Collector asserts a duplicate dispute |
It must reasonably meet the same-prior-timely-dispute/already-answered/no-new-material-information conditions. Collection pauses until the reasoned duplicate notice with prior-response reference, or verification, is sent. |
S017, §1006.38(a)(1), (d)(2)(ii), comments. H; a new canceled check can be material. |
| S_AZ-P07-C080 |
Collector sends required disclosures |
Delivery must reasonably be expected to give actual notice in a retainable, later-accessible form. Known undeliverability defeats that attempt; last-known-address mail has a qualified safe harbor. |
S017, §1006.42(a)(1), comments 1–4. H. §42(a)(2) narrowly excepts certain standalone identity/opt-out disclosures. |
| S_AZ-P07-C081 |
Required follow-up notice or verification/original-creditor response is sent electronically |
§42(b) invokes E-SIGN §101(c) for the listed follow-up and response disclosures. It does not list an initial electronic validation notice or the duplicate-notice alternative in the same way; other delivery/contact duties still apply. |
S017, §1006.42(b); §§1006.34(a)(1)(i)(B), .38(c), (d)(2)(i), (ii)(A). H; no blanket electronic-contact permission. |
| S_AZ-P07-C082 |
Collector relies on E-SIGN consumer consent |
Affirmative, unwithdrawn consent requires the statutory advance disclosures and electronic ability demonstration; withdrawal and material technology changes have specified consequences. |
S013, §7001(c)(1)(A)–(D), (2)–(4), (6). H; ordinary possession of an email address is insufficient. |
| S_AZ-P07-C083 |
Collector seeks to resume after verification/original-identity pause |
Statute requires obtaining and mailing the qualifying material; Regulation F provides the compliant written/electronic sending route. Mere internal verification fails; universal actual reading/receipt is not the resumption trigger. |
S013, §1692g(b); S017, §1006.38(c), (d)(2), §1006.42. H; other stops and Arizona investigation remain. |
| S_AZ-P07-C084 |
Collector relies on Clark verification standard |
Confirmation of the amount claimed, with the actual creditor information/itemized statement in that case, satisfied §1692g. It did not resolve separate misleading-amount liability or Arizona investigation duties. |
S030, majority §I, verification paragraphs; S002, R20-4-1521. L/HR; no universal original-contract, affidavit or trial-proof rule established. |
| S_AZ-P07-C085 |
Consumer does not dispute or collector supplies validation |
Non-dispute is not a legal admission. Validation does not establish ownership, judgment-level proof or discharge status; a communication pause does not itself extinguish the obligation. |
S013, §1692g(c); S017, §1006.38(d)(1); bounded inference from C067–C084. H for non-admission; analytical boundary for remaining propositions. |
| S_AZ-P07-C086 |
Collection occurs during validation period |
Activity must not overshadow or contradict dispute/original-creditor rights. The period alone is not an automatic collection moratorium; a qualifying pause or other restriction changes that. |
S013, §1692g(b); S017, §1006.38(b), (c), (d). H. |
| S_AZ-P07-C087 |
Collector uses a model notice or translation |
Model Form B-1 is optional and supplies only the stated information/format/overshadowing safe harbors when properly used. Translation must meet applicable accuracy/consistency conditions. |
S017, §1006.34(d)–(e), §1006.38(b)(2). H text; actual B-1 image/form inspection held. |
| S_AZ-P07-C088 |
Consumer also faces a suit or limitation question |
Validation/dispute provisions do not themselves calculate an answer deadline, extend a court deadline, determine claim accrual or decide standing. No such actual calendar is resolved here. |
S013, §1692g; S017, §§1006.34, .38, .30(d)(3); express scope boundary. H as bounded non-determination; governing court/limitations bodies deferred. |
| S_AZ-P07-C089 |
Consumer seeks public information/complaint route |
CFPB’s public page identifies debt-collection complaints and routing. Submitting a complaint is distinct from a qualifying dispute or court response. |
S032, complaint subjects/process; C072/C076/C088. H guidance; nothing submitted. AG route held under S033. |
2.6 Version, effective-date and interpretation limits
| Claim ID |
Predicate |
Finding |
Authority / confidence |
| S_AZ-P07-C090 |
Current Arizona conduct numbering |
2022 ch.59 §§51/53 amended §§32-1004/1051; March 24 approval differs from September 24 effectiveness. Current §1004(D) retains one older “2 through 7” reference; no nonexistent current paragraph 7 is invented. |
S001, S004–S006. H text; authoritative cleanup/harmonization of that residual reference not established. |
| S_AZ-P07-C091 |
Selected Arizona statutory currentness |
Inspected 2023–2026 TOSA ranges, election index and relevant delayed-date list did not identify changes to the four selected sections. |
S007–S012. H for index observations; bounded, not an all-law certificate. |
| S_AZ-P07-C092 |
Relevant 2023 Arizona rule amendment |
Final notice specifies October 2, 2023 effectiveness, distinct from September 1 publication. |
S003, item 3, p.1961/PDF46; operative rule pages. H. |
| S_AZ-P07-C093 |
Arizona rule currentness after posted supplement |
Supplement 25-4 supplies the read text; failed 2026 Register routes prevent exhaustive later-rule reconciliation. |
S002, S034. HR/P. |
| S_AZ-P07-C094 |
Modern Regulation F communication/validation requirements |
The 2020 and 2021 final rules identify November 30, 2021 commencement. The fictional 2026 models are later; no pre-effective retroactive notice conclusion is made. |
S018–S019, DATES. H. |
| S_AZ-P07-C095 |
Later federal technical amendments |
2022 corrections became effective November 1, 2022; relevant 2023 contact changes became effective April 19, 2023. The §38 mirror’s internal-reference typo is not used to alter electronic-submission rights. |
S020–S021; S016–S017. H. |
| S_AZ-P07-C096 |
Source currency versus access |
OLRC states October 15, 2026 law currency; eCFR displays October 23 Title 12 currency; actual research access was October 27 Pacific. These are different dates. Individual opening times remain unknown. |
S013, S016; research access record. H within recorded limits. |
| S_AZ-P07-C097 |
Judicial authority and later treatment |
Only identified published majority holdings are relied on. McAdory’s treatment of Henson and Riggs’s treatment of Camacho were read. No complete citator, all-later-treatment, Arizona-state-court binding-status or unpublished-citation certification is made. |
S024–S031 and bounded official searches. L; no unpublished opinion used. |
3. What the published decisions actually establish
This table records posture and holding separately from the legal propositions above.
| Decision / claims |
Material facts and posture actually read |
Majority holding and disposition |
Limit that matters here |
| Henson — C009 |
Purchaser sought to collect defaulted automobile debts it owned; dismissal was under review. |
Supreme Court affirmed the result under the owed-another branch. Acquisition after default did not itself make own-account collection collection for another. |
Principal-purpose question expressly reserved. No blanket debt-buyer exemption. S024, slip p.3 and pp.5–11. |
| McAdory — C010 |
Complaint alleged a debt buyer’s business centered on collecting purchased retail debt through third-party collectors; district court dismissed. |
Published majority reversed/remanded: outsourcing did not avoid principal-purpose classification on the alleged facts. |
Pleading-stage actor holding, not final proof of every alleged act or vicarious liability. Majority distinguished Henson. S025, pp.11–17. |
| Heintz — C011 |
Lawyer’s automobile-debt collection activity included litigation and a settlement communication; the district court had recognized an attorney exclusion. |
Supreme Court affirmed reversal of the exemption-based dismissal; regular litigation collection can fall within the Act. |
It does not make every legal communication unlawful. Later statutory pleading exceptions must be separately applied. S026, pp.292–299. |
| Obduskey — C012 |
Firm undertook Colorado nonjudicial foreclosure steps; dismissal and appellate affirmance were reviewed. |
Supreme Court affirmed the limited-purpose treatment for the conduct at issue. |
Ordinary money collection, other collector business and reserved judicial-foreclosure questions cannot be collapsed into that holding. S027, slip pp.12–14. |
| Hernandez — C065 |
An automobile-debt collector was followed by a law firm whose initial communication did not supply the required validation protections. Summary judgment favored the law firm. |
Ninth Circuit reversed/remanded; the successive collector’s own initial communication triggers §1692g. |
Collector status was conceded; this was not a general agency/exemption determination. S028, pp.25–26. |
| Camacho — C074 |
A consumer-debt letter expressly required all disputes to be written. Denial of dismissal was certified for interlocutory review. |
Ninth Circuit affirmed and remanded: §1692g(a)(3) does not impose that universal writing condition. |
Written steps remain necessary for the specific verification/original-creditor pause. Footnote 4 reserved a further question about affirmative rights arising from oral dispute. S029, Discussion, Conclusion, fn.4. |
| Clark — C041/C084 |
Disputed medical billing; itemized creditor information; a cease-contact direction followed by the consumer’s request to the collector’s lawyer. Cross-summary-judgment rulings were reviewed. |
Affirmed in part, reversed in part, remanded. The actual verification satisfied §1692g; cease-contact waiver required a knowing, voluntary, limited analysis, with disputed facts concerning another actor’s callback. |
Verification did not dispose of the separate false-amount theory. The dissent’s broader waiver view is not the majority rule. Arizona R20-4-1521 was not resolved. S030, majority §I and disposition. |
| Riggs — C075 |
Undisputed automobile-deficiency collection; notice placed written-verification language beside a general response statement. Partial summary judgment for collector was appealed. |
Ninth Circuit affirmed the preserved theory: the assumed implication did not equal Camacho’s express written-only condition. Other challenges were not preserved. |
Historical notice and preserved claims only; no present Regulation F form approval. S031, Parts III–IV, pp.6534–6538/PDF8–12. |
The two Justia sources are disclosed reproductions of primary opinions after failed official routes. Their headnotes, summaries and metadata were not substituted for holdings. Precedents quoted within these opinions were not treated as separately opened authorities.
4. Eighteen fictional actor/channel/workflow postures
Each posture is new and hypothetical. “Potentially qualifies” means the stated legal predicate is illustrated, not that an actual collection act is authorized.
| Posture |
Fictional facts |
Conditional result and adverse branch |
Claim references |
| P01 — Original creditor |
A household-services seller calls about its own invoice using its true name. |
The owed-another branch is not established merely by the call. A different-name collection operation or different principal-purpose facts require another analysis. Arizona/general consumer law is not cleared. |
C001, C003–C004, C013–C014 |
| P02 — Outsourcing buyer |
A purchaser’s alleged principal business is buying household debts and earning receipts through hired collectors. |
Outsourcing does not remove the principal-purpose inquiry. Actual business evidence and responsibility for a particular message remain unproved. |
C009–C010 |
| P03 — Purchase after default |
A business owns a purchased defaulted account, but its principal purpose and regular activities are unknown. |
Defaulted purchase alone supplies neither a universal exemption nor complete coverage. |
C003, C007, C009–C010 |
| P04 — Servicer timing |
One servicer obtained account A before default and account B after default. |
The nondefault-at-obtaining exclusion can matter to A; B requires full actor testing. A database’s “default” label is not conclusive evidence. |
C007 |
| P05 — Affiliate |
A shared-services company collects only family-company accounts. |
Federal affiliate exclusion still requires that its principal business not be debt collection. Arizona’s institutional-affiliate conditions are different. |
C006, C014 |
| P06 — Employee or contractor |
An individual works under a regular salary for a creditor; another is an independent contractor using a collection trade name. |
Employment, creditor-name and actual role predicates distinguish them. Labels do not settle either jurisdiction’s classification. |
C004–C005, C014 |
| P07 — Lawyer versus security-only firm |
One lawyer regularly demands consumer payments; another performs only the described nonjudicial-security steps. |
Heintz and Obduskey address different predicates. Adding an ordinary money demand can require fresh analysis. |
C011–C012 |
| P08 — Mixed-purpose account |
Equipment is used partly at home and partly in a business. |
Federal primary-purpose classification requires facts; Arizona’s general definition does not automatically adopt the federal restriction. |
C001, C013 |
| P09 — Counsel known |
Consumer identifies counsel and asks an Arizona agency to communicate through counsel. |
State stop-contact text applies if the agency is covered. Federal counsel exceptions do not automatically override the state rule. |
C023, C036–C037 |
| P10 — Workplace ban |
Consumer says personal collection calls are prohibited at work; home calls were unanswered. |
The failed-home-attempt condition does not remove the federal known-employer prohibition. |
C021, C035 |
| P11 — Friend contacted |
Collector asks a friend for a current address. |
A compliant location inquiry differs from revealing a balance or asking the friend to pressure payment. Repeated contact requires a stated exception. |
C022, C038–C039 |
| P12 — Voicemail |
Collector proposes a voicemail with only federal LCM fields. |
It may satisfy the federal content category on the assumed facts. Arizona role-identification compatibility remains unresolved; no production script is approved. |
C018, C054–C055 |
| P13 — Two debts, one person |
Calls concern debts A and B; a later incoming conversation addresses both. |
Counts and conversation restrictions must be reconciled separately for each debt. A small combined total does not eliminate the post-conversation presumption. |
C049–C053; Model 2 |
| P14 — Electronic opt-out |
Consumer texts STOP but later emails a written request to an accepted address. |
Text restriction remains. The consumer’s email does not automatically consent to a text response or satisfy the collector’s E-SIGN predicates. |
C060–C062, C077, C081–C082 |
| P15 — Oral then written dispute |
Consumer first orally says the bill was paid, then timely sends a written dispute. |
Oral dispute has legal significance; the federal written pause begins on receipt of the qualifying submission. Arizona investigation duties are separately tested. |
C028, C047, C074, C076 |
| P16 — Original identity and successor |
A successor collector receives a timely written request for the original creditor’s name/address. |
Its own notice duty and the identity-request pause must be satisfied. Naming the current creditor without the prescribed same-creditor determination is insufficient. |
C065, C072–C073 |
| P17 — Silence or late request |
Consumer remains silent, then requests information after every assumed candidate period has expired. |
Silence is not admission. The special timely-written federal pause is not established by these facts; state information duties and other prohibitions still require testing. |
C025–C028, C076, C085 |
| P18 — Paid, mistaken identity or discharged |
Consumer asserts mistaken identity, prior payment or discharge, but no underlying records are supplied in this hypothetical. |
Covered Arizona agency must follow its evidence/investigation rule. The allegation does not itself establish payment, discharge, ownership or eligibility. |
C027–C028, C084–C085 |
5. Four worked event and timing examples
Shared assumptions
These are conditional chronology models, not actual filing calendars or collection permissions.
- Each debt is assumed to be an ordinary personal/family/household obligation.
- Federal collector status is stipulated solely for the model. Arizona-rule observations additionally assume a covered Arizona agency.
- No actual court order, pending case, contractual waiver, bankruptcy status, actor exemption, time-zone fact or communication record has been established.
- Balance = B throughout. No interest, fee, payment, credit or settlement is modeled. Therefore change in consumer payments = 0; change in collector receipts = 0; change in balance = 0. Sending a notice is not a payment.
- Dates are fictional 2026 dates. Integer day counting needs no rounding.
- The initial five-day dispatch rule, five-day assumed-receipt calculation, 30-day validation period and seven-day telephone presumptions are kept separate.
- Models deliberately avoid deciding a last-day mailing-versus-receipt controversy or importing court weekend/holiday extensions.
Model 1 — Initial contact, dispatch, assumed receipt and a returned notice
Authority: C064, C070–C071, C080; S013 §1692g(a); S017 §1006.34(a), (b)(5), comments 34(b)(5)-1–2; S023 §6103(a).
Base sequence
- Monday, March 2: first covered oral communication. Complete validation information is not supplied.
- Tuesday, March 3: a proper paper notice is mailed to the correct address. This is one day after the initial contact, avoiding a contested five-day endpoint.
- For the earliest permitted assumed-receipt date, count after March 3:
| Date |
Treatment |
Running counted days |
| Wednesday, March 4 |
Count |
1 |
| Thursday, March 5 |
Count |
2 |
| Friday, March 6 |
Count |
3 |
| Saturday, March 7 |
Exclude |
3 |
| Sunday, March 8 |
Exclude |
3 |
| Monday, March 9 |
Count |
4 |
| Tuesday, March 10 |
Count |
5 |
No §6103(a) holiday occurs in this interval.
Conditional result: Assumed receipt = March 10. The regulatory period starts when information is provided, here March 3, and ends 30 days after the selected receipt date.
Plain-text arithmetic:
- March 11–31 = 21 calendar days.
- April 1–9 = 9 calendar days.
- 21 + 9 = 30.
- Calculated assumed-receipt endpoint = Thursday, April 9.
Actual-receipt branch: If actual receipt was March 9, arithmetic using actual receipt produces Wednesday, April 8. Comment 34(b)(5)-1 permits the collector’s calculated assumed-receipt endpoint despite later learning a different receipt date. A dispute submitted and received March 18 is deliberately inside both calculations; this example does not adjudicate a contested last-day submission.
Adverse delivery branch: Suppose the March 3 notice is returned undelivered on March 6 and the consumer received no validation information elsewhere. A correctly addressed replacement is sent Tuesday, March 10.
- Count March 11, 12, 13 = days 1–3.
- Exclude March 14–15.
- March 16 = day 4; March 17 = day 5.
- New assumed receipt = March 17.
- March 18–31 = 14 days; April 1–16 = 16 days.
- 14 + 16 = 30.
- Updated endpoint = Thursday, April 16.
The replacement calculation does not establish that the original delivery complied with the initial five-day duty or erase any earlier violation. Actual address, delivery and notice-content facts remain necessary. Consumer Financial Protection Bureau+1
Model 2 — Complete call ledger, two debts and the conversation restriction
Authority: C049–C053; S017 §1006.14(b)(2)–(4) and comments.
Assume one consumer P, two distinct debts A and B, valid earlier validation, no pending dispute pause, no known counsel/workplace/medium restriction, and local times as shown. Each unanswered attempt is documented as concerning the specified debt.
Base ledger: March 2–8
| Event |
Date/time |
Direction, person and debt |
Connection/result |
Frequency treatment |
| 1 |
Mon. March 2, 10:00 |
Outgoing to P, A |
Rings; unanswered |
A +1 |
| 2 |
Mon. March 2, 15:00 |
Outgoing to P, A |
Busy; not connected |
Excluded +0 |
| 3 |
Tue. March 3, 11:00 |
Outgoing to P, A |
Rings; unanswered |
A +1 |
| 4 |
Tue. March 3, 16:00 |
Outgoing to P, B |
Rings; unanswered |
B +1 |
| 5 |
Wed. March 4, 10:00 |
Outgoing to P, A |
Voicemail referring to A |
A +1; content/privacy separately assumed compliant |
| 6 |
Thu. March 5, 11:00 |
Outgoing to P, A |
Rings; unanswered |
A +1 |
| 7 |
Thu. March 5, 16:00 |
Outgoing to P, B |
Rings; unanswered |
B +1 |
| 8 |
Fri. March 6, 10:00 |
Incoming from P, A and B |
Conversation about both |
No outgoing-call increment; conversation trigger for A and B |
Reconciliation:
- Physical outgoing attempts = 7.
- Counted outgoing calls = 6.
- Excluded unconnected attempt = 1.
- Debt A counted calls = 4.
- Debt B counted calls = 2.
- Incoming conversations = 1, concerning both debts.
Conversation-period calculation:
- March 6 = day 1.
- March 7–12 = days 2–7.
- March 13 is beyond this conversation’s seven-day period.
That last statement addresses only this presumption. It is not permission to call on March 13.
Adverse branch A — Low count, but conversation restriction
An unconsented call about A on Monday, March 9 falls within March 6–12. It can trigger the violation presumption despite A’s count being below eight.
Adverse branch B — Four additional attempts
Instead add these four separate calls:
| Added event |
Date/time |
Person/debt |
Result |
Count |
| B1 |
Sat. March 7, 10:00 |
P/A |
Rings unanswered |
A +1 |
| B2 |
Sat. March 7, 15:00 |
P/A |
Rings unanswered |
A +1 |
| B3 |
Sun. March 8, 10:00 |
P/A |
Rings unanswered |
A +1 |
| B4 |
Sun. March 8, 15:00 |
P/A |
Rings unanswered |
A +1 |
Now A = 4 + 4 = 8 in March 2–8; B remains 2. Total physical outgoing attempts = 11; counted = 10; excluded busy attempt = 1. The eighth A call exceeds seven, and all four added calls occur inside the post-conversation period. Weekend days are included in these consecutive-day calculations.
Consent branch — Separate alternative
Instead, during the March 6 conversation P specifically requests one A callback on March 9. Assuming valid direct consent and no overriding restriction, that callback can qualify for the frequency exclusion.
If a conversation occurs on March 9:
- The new conversation period runs March 9–15, counting March 9 as day 1.
- The prior call consent ends with that conversation.
- An unconsented March 10 call requires a new analysis and falls within the new conversation period.
None of these totals is a recommended contact volume. Harassment, content, privacy and state restrictions remain independently relevant. Consumer Financial Protection Bureau+1
Model 3 — Oral dispute, written pause, verification obtained, verification sent
Authority: C027–C028, C047, C074, C076–C084; S013 §1692g(b); S017 §§1006.38(d)(2), .42; S002 R20-4-1521.
Use Model 1’s valid notice and nonboundary dates.
- Thursday, March 12: consumer orally says the debt was paid.This is not legally meaningless.It can affect disputed reporting and Arizona investigation duties.It does not alone establish the special federal written-dispute pause.
- Monday, March 16: consumer mails a written dispute.
- Wednesday, March 18: collector receives it.Both submission and receipt are comfortably within both Model 1 candidate periods.Federal pause begins on receipt, March 18.
- Monday, March 23: collector obtains creditor confirmation internally.Obtaining information without the required response does not end the pause.
- Tuesday, March 24: collector properly mails qualifying verification to the correct address, with no known delivery problem.
- Friday, March 27: consumer actually receives it.
Conditional positive branch: The federal verification pause can end upon proper sending on March 24, rather than universally waiting until March 27. That assumes adequate verification and compliant delivery.
Adverse branches:
- If the Arizona agency has not completed the investigation required by R20-4-1521 after supplying evidence, federal sending alone does not resolve that state restriction.
- If the collector knows the response is undeliverable, §1006.42’s delivery condition is not satisfied by the failed attempt.
- If the dispute concerns only a genuinely separable portion, the statutory portion language matters; the example does not invent a separable amount.
- A prior all-contact cease notice, counsel restriction or channel restriction is not erased by verification.
- No general 30-day collector-response deadline, discharge, judgment proof or court-deadline extension is calculated.
Balance remains B, with no payment or collector receipt. Consumer Financial Protection Bureau+2
Model 4 — Invalid electronic follow-up, paper notice, text opt-out and original-creditor request
Authority: C060–C062, C070, C072–C073, C077, C080–C083; S017 §§1006.6(e), .14(h), .34, .38(c), .42; S013 §7001(c).
- Monday, March 2: initial oral collection communication without complete validation information.
- Tuesday, March 3: collector emails the required follow-up notice, but lacks the necessary E-SIGN §101(c) consent.Ordinary email permission does not establish compliance for this designated follow-up disclosure.This model does not start a valid notice clock from that defective route.
- Wednesday, March 4: proper paper notice is sent, two days after initial communication.
Assumed-receipt calculation:
- March 5 = day 1; March 6 = day 2.
- Exclude March 7–8.
- March 9 = day 3; March 10 = day 4; March 11 = day 5.
- Assumed receipt = Wednesday, March 11.
- March 12–31 = 20 calendar days.
- April 1–10 = 10 calendar days.
- 20 + 10 = 30.
- Calculated endpoint = Friday, April 10.
- Monday, March 9: consumer texts STOP through the existing text route.The destination/channel restriction applies.It is not necessarily an all-channel refusal or cease notice.
- Wednesday, March 18: consumer sends an original-creditor name/address request to an email address through which the collector accepts consumer communications; collector receives it that day.The consumer’s writing does not require the consumer to complete E-SIGN §101(c) formalities.The timely request triggers the original-creditor-information pause.
- Friday, March 20: collector obtains the information internally. Pause remains.
- Monday, March 23: collector properly mails the original-creditor information.
- Wednesday, March 25: consumer receives it.
Conditional result: Proper sending on March 23 can satisfy this federal resumption condition, subject to other applicable restrictions.
Adverse branch: Sending the required response only by text to the opted-out number, without the required electronic-disclosure predicates, does not establish compliant response. The consumer’s accepted email request does not authorize a text reply. If original and current creditor are the same, the collector must satisfy the reasonable-determination/notice/reference alternative; it cannot simply omit the response.
No debt ownership, fee entitlement or court deadline is established by this sequence. Consumer Financial Protection Bureau+2
6. Granular component coverage and exact remaining work
Status key: Answered means the bounded legal question is supported by the identified bodies. Partial means text is established but an identified interpretation/currentness element remains. Held means necessary evidence was not obtained. Deferred means intentionally outside PASS-07. None is coordinator acceptance.
6.1 Core actors, communications and channels
| Coverage row |
Requested issue |
Status / claim references |
Exact missing evidence or next action |
| K01 |
Personal/family/household debt |
Answered — C001 |
Actual transaction purpose remains unknown. |
| K02 |
Business and mixed-purpose accounts |
Partial — C001, C013 |
Determine primary purpose from authorized facts; no inference from borrower identity. |
| K03 |
Original creditor / false other name |
Answered — C003–C004 |
Actual name use and business model held. |
| K04 |
Buyer: principal purpose versus owed another |
Answered — C009–C010 |
Actual operating evidence and responsibility for conduct held. |
| K05 |
Servicer and default timing |
Partial — C007 |
Contract/default/acquisition facts and any disputed default construction remain. |
| K06 |
Affiliate predicates |
Answered — C006, C014 |
Ownership, exclusive clientele and principal business unverified. |
| K07 |
Employee versus contractor |
Answered — C005, C014 |
Employment relationship and name used unverified. |
| K08 |
Attorney collection |
Answered — C011, C014 |
Actual regularity, role and state exemption conditions held. |
| K09 |
Security-only versus money demand |
Partial — C012 |
Full foreclosure/repo and mixed-conduct classification deferred. |
| K10 |
Arizona definition and retained exempt-actor conduct |
Partial — C013–C014 |
No actual licensing/exemption decision; P06 remains separate. |
| K11 |
Remote Arizona contact |
Partial — C015 |
Responsive territorial/choice-of-law authority and actual contact facts remain. |
| K12 |
Consumer, third parties and representatives |
Answered — C001–C002, C038 |
Actual representative authority and independent liability held. |
| K13 |
State versus federal classification |
Answered — C003, C013–C017 |
No cross-regime exemption inferred. |
| K14 |
Special statutory actor exclusions |
Partial — C008, C017 |
Full bad-check-program and special-sector cross-reference eligibility not established. |
| K15 |
Time/place and consumer knowledge |
Answered — C033–C034 |
Actual location, knowledge and communication time held. |
| K16 |
Workplace calls |
Answered — C021, C035 |
Employer policy, knowledge and specific consent/order held. |
| K17 |
Known counsel |
Partial — C023, C036 |
State/federal distinctions established; actual representation and reasonable-response facts unknown. |
| K18 |
Direct prior consent / court permission |
Answered — C037 |
Actual consent scope and court order unexamined. |
| K19 |
Third-party collection disclosure |
Answered — C022, C038 |
Identity, obligation and exception facts held. |
| K20 |
Location inquiry |
Answered — C039 |
Prior contacts, correction basis and counsel knowledge held. |
| K21 |
Written cease / refusal and exceptions |
Answered — C024, C040–C041 |
Receipt, exact requested scope and any waiver facts held. |
| K22 |
Harassment, deception and threats |
Answered — C019–C020, C042–C043 |
Actual words, pattern, intent and lawful-action basis held. |
| K23 |
Added fees/interest |
Partial — C029–C031, C045 |
Actual contract/law basis and state-law-only charge reconciliation remain. |
| K24 |
Postdated instruments |
Answered narrowly — C046 |
No instrument, deposit date or payment authorization examined. |
| K25 |
Reporting known disputed debt |
Answered narrowly — C047 |
Actual reporting/knowledge and full FCRA duties deferred. |
| K26 |
Contact before furnishing |
Answered narrowly — C048 |
Delivery/bounce monitoring and specialty-agency exception facts held. |
| K27 |
Call-attempt classification |
Answered — C049, C051 |
Actual connected/unconnected records held. |
| K28 |
Conversation and following period |
Answered — C050 |
Actual conversation subject and date held. |
| K29 |
Call exclusions and consent |
Answered — C051–C052 |
Actual consent, expiration, recipient and revocation held. |
| K30 |
Multiple-debt/person counts |
Answered — C053; Model 2 |
Actual allocation and any special grouping facts held. |
| K31 |
Federal LCM contents |
Answered — C054–C055 |
Actual voicemail and intended recipient unknown. |
| K32 |
LCM versus Arizona identification |
Held — C018, C055 |
Obtain authoritative responsive interpretation of R20-4-1507/-1520 and §1006.2(j); none opened in bounded official searches. |
| K33 |
Email acquisition/transfer routes |
Answered conditionally — C056–C058 |
Procedures, notice, opt-out, domain and knowledge records held. |
| K34 |
Text route / 60-day condition |
Answered conditionally — C059 |
Actual text/consent/reassignment evidence held; no database query made. |
| K35 |
Electronic opt-out and oral medium stop |
Answered — C060–C061 |
Actual wording, destination and scope held. |
| K36 |
Employer-provided email |
Answered — C062 |
Knowledge and qualifying route unverified. |
| K37 |
Social media, postcards and envelopes |
Answered narrowly — C063 |
Actual visibility/content and other privacy laws deferred. |
6.2 Validation and dispute workflow
| Coverage row |
Requested issue |
Status / claim references |
Exact missing evidence or next action |
| K38 |
Initial communication / five-day route |
Answered — C064 |
Actual first covered communication and completeness held; no contested five-day endpoint calculated. |
| K39 |
Successive collector’s notice |
Answered — C065 |
Actual succession and communications held. |
| K40 |
Formal pleading / mandatory-notice exclusions |
Answered — C066 |
Classify actual document; full litigation/bankruptcy branches deferred. |
| K41 |
Required validation fields |
Answered — C067 |
Actual notice not inspected or approved. |
| K42 |
Itemization-date choice and consistency |
Answered — C068 |
Actual reference-date records and amount ascertainability held. |
| K43 |
Amount versus ownership/evidence |
Answered boundary — C069, C084–C085 |
Ownership chain and judgment-level evidence deferred. |
| K44 |
Five-day assumed receipt / 30-day period |
Answered — C070; Model 1 |
Actual provision/receipt dates held. |
| K45 |
Actual versus assumed receipt |
Partial — C071 |
Commentary read; disputed last-day submission/receipt litigation not resolved. |
| K46 |
Wrong address, bounce and replacement |
Answered — C071, C080 |
Actual delivery records and earlier compliance consequences held. |
| K47 |
Oral dispute |
Answered — C074–C075 |
No universal written-only rule; particular message and reporting facts held. |
| K48 |
Timely written dispute / portion pause |
Answered — C076–C078 |
Actual submission, receipt, timeliness and separable disputed portion held. |
| K49 |
Original-creditor identity request |
Answered — C072–C073 |
Actual original/current identity and response records held. |
| K50 |
Duplicate disputes / new material information |
Answered — C079 |
Compare actual submissions and prior response; no duplicate finding here. |
| K51 |
E-SIGN and accepted electronic writing |
Answered — C077, C081–C082 |
Actual consent, withdrawal, capabilities and accepted-medium records held. |
| K52 |
Verification content |
Partial — C084 |
Bounded federal holding read; no universal evidentiary checklist or actual adequacy finding. |
| K53 |
Arizona five-day information / free specified copies |
Answered posted text — C025–C026 |
Actor applicability and later-Register check remain. |
| K54 |
Arizona evidence / investigation |
Answered posted text — C027–C028 |
Actual evidence, asserted grounds and investigation completion held. |
| K55 |
Verification obtained versus sent/received |
Answered — C083; Model 3 |
Adequacy, proper delivery and independent restrictions held. |
| K56 |
Silence, admission and extinguishment |
Answered boundary — C078, C085 |
Debt validity, payment and discharge remain unproved. |
| K57 |
Overshadowing / ongoing collection |
Answered — C086–C087 |
Actual notice layout and surrounding conduct held; B-1 image not read. |
| K58 |
Court deadlines and accrual distinguished |
Deferred beyond boundary — C088 |
Read applicable court rules/served documents or accrual authorities in separate passes; no actual calendar here. |
6.3 Currentness, source failures and examples
| Coverage row |
Requested issue |
Status / claim references |
Exact missing evidence or next action |
| K59 |
Selected Arizona statute currentness |
Partial — C091, C096 |
Bounded TOSA checks completed; no all-enactment certificate. |
| K60 |
2022 enactment and renumbering |
Answered — C090 |
Residual §1004(D) cross-reference interpretation remains unestablished. |
| K61 |
2023 rule adoption / commencement |
Answered — C092 |
Earlier historical adoptions quoted in notes not separately reopened. |
| K62 |
Post-Supplement-25-4 rule changes |
Held — C093, S034 |
Read accessible official cumulative Register index and responsive final notices. |
| K63 |
Federal operative text / effective dates |
Answered within sources — C094, C096 |
No full all-litigation stay/vacatur certification. |
| K64 |
Technical corrections / mirror error |
Answered — C095 |
Use corrected eCFR/final-notice cross-reference; do not copy mirror typo. |
| K65 |
Published majority bodies and posture |
Answered narrowly — C009–C012, C041, C065, C074–C075, C084 |
Full subsequent-history research remains open. |
| K66 |
Official opinion failures / reproductions |
Partial — S029–S030 |
Official files for these two opinions remain unobtained; disclosed opinion reproductions read. |
| K67 |
Unpublished opinions / citation restrictions |
Not invoked — C097 |
No unpublished opinion relied on; if later used, first verify governing citation rule and format. |
| K68 |
Federal whole-chapter and cross-reference failures |
Resolved for material text — S013–S014, S023, S036–S037 |
Failed editions themselves remain unread; no absence inference. |
| K69 |
Arizona AG guidance route |
Held — S033 |
Obtain current accessible official page via a valid official index. |
| K70 |
CFPB public information route |
Answered as guidance — C089 |
No complaint, account or submission made. |
| K71 |
Model 1: notice/receipt chronology |
Completed conditional example |
Actual delivery facts and boundary disputes held. |
| K72 |
Model 2: full call reconciliation |
Completed conditional example |
Actual logs, contents, consent and state compatibility held. |
| K73 |
Model 3: oral/written/verification sequence |
Completed conditional example |
Actual dispute, evidence and investigation held. |
| K74 |
Model 4: electronic delivery/opt-out/original identity |
Completed conditional example |
Actual E-SIGN and communication records held. |
| K75 |
At least 12 distinct fictional postures |
Completed: 18 postures |
Examples are not eligibility or permission decisions. |
6.4 Territory, forum and private-fact holds
| Territory/fact row |
Subject |
Status / relevant claims |
Exact missing evidence or next action |
| T01 |
Arizona statewide statutory/rule baseline |
Partial — C013–C032, C090–C093 |
Later-Register reconciliation and actual actor applicability remain. |
| T02 |
Interstate/remote collection into Arizona |
Held beyond bounded text — C015–C016 |
Responsive jurisdiction, choice-of-law and contact facts required. |
| T03 |
County court/local practice |
Deferred — C088 |
No county inventory or individual county rule/form validation performed in P07. Any relevant local rule requires its own official-body check. |
| T04 |
Municipal/local ordinances and administrative practices |
Held |
No local conduct ordinance inventory verified; check the actual relevant locality only in an authorized later pass. |
| T05 |
Tribal law, jurisdiction and sovereign actors |
Held |
No tribal code, agreement, status or jurisdictional facts researched. |
| T06 |
Federal versus Arizona state-court precedent treatment |
Partial — C097 |
Federal published holdings identified; no separate state-court precedential-status dossier or forum selection. |
| T07 |
Other states, territories and countries |
Deferred |
Federal definitions do not supply another jurisdiction’s complete conduct law. No country or parent acceptance. |
| T08 |
Actual debt, contract, collector, consent, delivery and calendar facts |
Held throughout |
No private records queried. Any later application requires separately authorized evidence; none is inferred here. |
6.5 Deferred families remain required work
| Deferred row |
Family |
Boundary preserved |
Exact later investigation |
| D01 |
Collection-agency licensing/security/application |
P06 remains separate and unreviewed |
Determine actual state license/exemption/security predicates in that component; no fees/bonds rerun here. |
| D02 |
Debt-management/settlement/credit-repair/CROA models and fees |
P01/P02 do not establish collector status |
Separate provider-model, agreement, fee and federal ancillary-law investigations. |
| D03 |
Full debt merits, validity, payment and identity theft |
Validation is not adjudication |
Obtain authorized merits evidence and applicable substantive law. |
| D04 |
Service and venue |
C088 boundary only |
Read governing court rules/statutes and actual service facts. |
| D05 |
Answers, default and vacatur |
No live deadline calculated |
Separate court-specific procedural investigation. |
| D06 |
Standing, ownership chain and trial evidence |
C069/C084 boundary only |
Published evidentiary/standing authorities and actual admissible records. |
| D07 |
Limitation, accrual, acknowledgment and revival |
P05 not imported |
Separate source-supported clock analysis. |
| D08 |
Judgment duration, renewal and execution |
No renewal premise |
Separate judgment-enforcement gateway. |
| D09 |
Earnings, bank accounts and property exemptions |
P03/P04 not imported |
Separate enforcement and exemption regimes. |
| D10 |
Homestead, foreclosure, repossession and secured debt |
C012 only |
Full security-enforcement law and facts. |
| D11 |
Damages, penalties, remedies and complete defenses |
No amounts supplied |
Separate statutory-remedy and controlling-case analysis; §1692k(c) used only for C056. |
| D12 |
TCPA, DNC and automated-contact consent |
Regulation F does not clear these |
Fresh FCC/statutory/case research before any contact conclusion. |
| D13 |
Full FCRA, reporting accuracy and reinvestigation |
C047–C048 only |
Full furnisher/CRA obligations and actual reporting facts. |
| D14 |
Privacy, data security and recording laws |
No privacy permission inferred |
Applicable federal/state/local privacy and consent law. |
| D15 |
Bankruptcy stay/discharge and military protections |
Allegations do not establish status |
Separate operative law, order/status and exception evidence. |
| D16 |
Tax, support, student, medical, utilities and other special sectors |
Ordinary consumer gateway only |
Debt-specific statutes and regulations, including any special notice rules. |
| D17 |
General Arizona consumer fraud and professional rules |
Original-creditor/attorney exclusion is not general immunity |
Separate statutes, professional rules and responsive holdings. |
| D18 |
Contract defenses, arbitration and choice of law |
No contract accepted or interpreted |
Actual authorized agreement and governing-law research. |
| D19 |
Minority, disability, government and special bad-check programs |
No special eligibility finding |
Read complete responsive cross-references and actual status predicates. |
| D20 |
Full collector record-retention, supervision and enforcement procedures |
Not established by these conduct excerpts |
Separate operative administrative and federal recordkeeping analysis. |
| D21 |
Complete state/country/parent dossier |
All broader categories remain open |
Separate focused passes and actual coordinator review; no A066/A097/A098 acceptance. |
Coverage counts are separate: 75 component/workflow/currentness/example rows; 8 territory/private-fact rows; 21 deferred-family rows. The 18 postures, four models, eight opinion analyses and source/claim registers are not duplicate accepted coverage.
7. Exact P01 deferred-row contribution crosswalk
The following provenance is user-supplied, including the coordinator review timestamp 2026-10-23T05:19:34.171103Z. The coordinator review file was not freshly opened in this pass.
| Original reviewed P01 topic |
Original disposition and next action, preserved |
Narrow P07 contribution |
Status that remains |
| “Full collection, litigation, limitations, debtor-property exemptions, secured debt, sectors, local and tribal law, contract defenses/choice of law, broader case law” |
“Excluded from completion of this pass; all remain open.” “Separate focused investigations are required. Nothing in this component supplies statewide or A066 acceptance.” |
Fresh communication/validation/dispute findings C001–C089, with version and authority limits C090–C097; corresponding K/T/D coverage rows. |
Original parent row remains component_partial_not_accepted_remaining_required_work as supplied. P07 contributes only this narrow slice. P02 renewal and P03–P06 unreviewed work are neither resolved nor accepted here. |
8. Researcher self-check
What was actually read. This pass opened the identified Arizona statutory bodies, the material Article 15 definitions/conduct rules, the responsive 2023 final adoption, the 2022 enacted amendment portions, selected official sections-affected indexes, the material federal Code and Regulation F bodies and official interpretations, and the identified published opinion portions. The source register distinguishes entire material opinions from partial opinion readings. It also separates operative law from indexes and guidance.
What was not established. The inaccessible 2026 Arizona Register routes prevent an exhaustive later-rule reconciliation. No authoritative body resolving Arizona identification duties against federal limited-content messaging was obtained. Current AG debt-collection guidance was not retrieved. Actual Model Form B-1 visual content was not inspected. No private actor, account, contract, default, representation, consent, delivery, court-calendar or discharge fact was verified.
Case-law limits. The report uses majority holdings and their actual procedural posture. It identifies the two reproduction hosts and their failed official routes. It does not treat host summaries, dissenting propositions, allegations or quoted underlying precedents as separately verified holdings. No unpublished opinion is relied on. The specified later treatment was read; complete subsequent-history or citator clearance was not performed.
Timing and arithmetic. The four models separate dispatch, receipt, validation, pause and telephone-count clocks. The call ledger reconciles every modeled attempt and conversation. No real deadline, payment, added fee, interest rate, monetary remedy or settlement is calculated.
Preserved holds. Missing evidence is not treated as nonexistence, permission or repeal. The K/T/D tables state the exact next investigation for each remaining issue. Public complaint information was read without contacting anyone or submitting anything.
This is a researcher self-check, not independent review. It supplies no actual consumer/provider authorization or overall state/parent acceptance.
END S_AZ PASS-07.