FDCPA Section 807 and AI: When Generated Messages Cross the False Representation Line
A Scripted Letter Can Be Wrong. A Generative System Can Be Wrong Differently, at Scale. TL;DR A collections letter written by a compliance team and approved once can be wrong, but it’s wrong in a way someone already reviewed and signed off on. A generative AI system composing a new message for every borrower, every […]
BNPL Collections in 2026: What Applies Now That the CFPB’s Credit-Card Classification Was Withdrawn
Building Toward a Rule the Bureau Itself Withdrew Solves Nothing TL;DR If your BNPL collections build is still oriented around satisfying the CFPB’s card-issuer classification, it’s worth pausing to check the date. The Bureau withdrew that rule in May 2025 and confirmed the following month it has no intention of bringing it back in that […]
Hardship Workflow Automation: How AI Routes Distressed Borrowers to the Right Programme
Two Borrowers in Identical Distress Shouldn’t Get Different Outcomes Because They Reached Different Agents TL;DR A borrower calls in genuinely struggling. Depending on which agent picks up, on their training, their caseload that day, their read of an ambiguous situation, that borrower gets routed to a forbearance conversation, a payment plan pitch, or nothing more […]
Credit Card Collections AI: How Revolving Behaviour Changes the Propensity Model
Your Installment Model Isn’t Underperforming on Cards. It’s Answering a Different Question. TL;DR A collections model that performs well on personal loans and auto loans, then quietly underperforms the moment it’s pointed at a credit card portfolio, isn’t a model that needs more data. It’s a model answering a question revolving credit doesn’t ask. Why […]
Mortgage Collections and Loss Mitigation AI: Meeting CFPB Servicing Rules Without Manual Intervention
An AI System That Contacts a Borrower Mid-Review Isn’t Efficient. It’s a Violation. TL;DR A mortgage servicer’s AI collections system flags a delinquent account for outreach. The borrower submitted a loss mitigation application eleven days earlier. It’s still under review. The system doesn’t know that, because nobody wired loss mitigation status into the contact decision. […]
NCA Section 86 and AI Collections: Real-Time Debt Review Integration for SA Credit Providers
TL;DR NCA Section 86, AI Collections, and the Case for Real-Time Debt Review Integration South African credit providers running AI-driven collections workflows face a compliance exposure that most batch-based systems cannot close: the gap between when a borrower applies for debt review and when the collections platform actually knows about it. NCA Section 86, as […]
NCA-Compliant AI Collections in South Africa: Debt Review, Conduct, and Section 129 Requirements
TL;DR South African credit providers deploying AI in collections face a compliance problem that batch-based systems cannot solve. The National Credit Act 34 of 2005 (NCA), as amended by the National Credit Amendment Act 2014, together with the NCR Guideline 2023 on AI automated systems, creates a regulatory framework where the timing of each contact […]
CFPB UDAAP and AI Collections: What Unfair, Deceptive, and Abusive Means for US Banks in 2026
TL;DR CFPB UDAAP Standards and AI-Driven Collections: What US Banks Must Address in 2026 The CFPB’s UDAAP authority now reaches directly into AI collections workflows at US banks, and the enforcement data from 2025 confirms that examiners are acting on it. The regulatory foundation sits in Dodd-Frank Section 1031, which grants the CFPB authority over […]
Winning the Deposit War
The Practitioners on Stage Valsan Ponnachath — Co-Founder, President and COO, iTuring Valsan leads product and commercial operations at iTuring. He has overseen AI deployments for some of the largest financial institutions in Asia, including the second-largest bank in India and the largest bank in Vietnam, and is now building iTuring’s US presence with a […]
POPIA Section 71 and AI Collections Decisions: What SA Credit Providers Must Be Able to Show
TL;DR South African credit providers using AI to drive collections decisions face a specific and increasingly enforced obligation under POPIA Section 71: the ability to explain any automated decision to the borrower and to the Information Regulator on demand. The Protection of Personal Information Act 4 of 2013 (POPIA) commenced in July 2021, with enforcement […]
