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UNITED STATES OF AMERICA
FEDERAL TRADE COMMISSION
WASHINGTON, D.C. 20580
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Division of Credit Practices
Bureau of Consumer Protection
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September 21, 1992
Ms. Betty Zbrzeznj
Colonial National Bank
P.O. Box 15480
Wilmington, DE 19850-5480
Dear Ms. Zbrzeznj:
This is in reply to your letter of August 17, 1992,
concerning whether communication of collection messages through
a translator service constitutes an impermissible third party
communication under the Fair Debt Collection Practices Act (copy
enclosed). In orally communicating with non-English speaking customers
about their debts, you wish to use interpreters to convey the
message in the appropriate language.
We believe that use of such a service falls within
the exception to Section 805(b) noted by the enclosed staff commentary
on the Act, namely, an "incidental contact" (p. 50104,
No. 3, second column) necessary to enable the collector to make
contact with and transmit a dunning message to the consumer. Thus,
we do not believe that use of such a service would violate Section
805(b).
Your interest in writing is appreciated.
Sincerely,
John F. LeFevre
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