Proposal of Debt Collectors, Inc. to locate its offices on or adjacent to the premises of its clients…

ADVISORY OPINIONS 1072 Proposal of Debt Collectors, Inc. to locate its offices on or adjacent to the premises of its clients. (File No. 743 7002, released

January 4, 1974, Digest 485)
Letter of Opinion
December 19, 1973
Dear Mr. Russell:

This is in response to your letter dated October 1, 1973, in which you requested an advisory opinion regarding a proposal of Debt Collectors, Ine. (DCI) to locate its offices on or adjacent to the premises of its clients.

It is the Commission’s understanding that DCI is a debt collection agency as that term is defined in the Commission’s Guides Against Debt Collection Deception (16 C.F.R. 237). It performs routine debt collection services for its clients such as serving notices, collecting payments and transmitting the funds to the client.

DCI proposes to locate its offices on or adjacent to premises of some of its clients but will make every effort to affirmatively disclose the fact that DCI is independent of them by doing such things as placing its corporate name on the entrances to the office, on the notices to debtors and on the stationery it uses.

Based on its understanding as outlined above, the Commission is of the view that debtors probably would not be deceived as to the true nature of the DCI offices on or adjacent to the client’s premises. Accordingly, it is the Commission’s opinion that implementation of the plan would not be violative of laws administered by the Commission, provided no evidence comes to light that debtors may be deceived.

By direction of the Commission.
Letter of Request
October 1, 1973