I thought flat rating only applied to attorneys whom perform no meaningful review of an account?
I don't see the link as a necessarily illegal service. I'm assuming that the phone drones at the CA just don't call the debtor morning noon and night.
It all would have to do with the content of the letter and whether the FDCPA notices were there. The 2nd letter is definitely all about the timing.
This was interesting - if the creditor fills out the form:
Quote:
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Check the box below to indicate that you have accurately described the past due account being placed for collection letter service, and to verify that you have supporting documentation for this delinquent debt
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