UNITED STATES OF AMERICA
September 21, 1992
Ms. Betty Zbrzeznj
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.
John F. LeFevre