# Regulation F's 7-in-7 rule in practice > How to count calls under 12 CFR 1006.14(b): what an attempt is, why counting runs per debt, the seven days after a conversation, and how both presumptions are rebutted. - Source: https://ottoforfirms.com/guides/call-frequency-in-practice/ - Publisher: Otto — https://ottoforfirms.com - Updated: 2026-07-29 Count per debt, not per consumer, and count connections rather than dial attempts. 12 CFR 1006.14(b)(2)(i) presumes compliance if a collector places no more than seven telephone calls to a particular person about a particular debt within seven consecutive days, and none within seven consecutive days after a telephone conversation about that debt; 1006.14(b)(2)(ii) presumes a violation above either line. Both presumptions are rebuttable, which is why a clean count is a defence and not a licence — the Bureau's own commentary lists a highly concentrated calling pattern as a factor that can rebut compliance even at six calls. The counting unit is the debt: "particular debt means each of a consumer's debts in collection", so a consumer with three placed accounts can lawfully be called twenty-one times in a week, and a dialer that counts per person will either under-call or mis-report. ## Key facts - A call that rings unanswered or reaches voicemail counts. A busy signal or an out-of-service tone does not. - Ringless voicemail is a telephone call for this rule. Text messages and emails are not. - Counting is per debt, except that student loans serviced under one account number count as one debt. - The seven days after a conversation start on the day of the conversation, and it does not matter who placed the call. - Consent given directly to the collector suspends counting for up to seven days, and expires on the next conversation. - Calls to a number the firm later learns is not that person's are not counted as calls to that person. ## What counts as an attempt Connection, not dialling. The commentary to section 1006.14(b)(3)(ii) draws the line precisely: "A debt collector's telephone call connects to the dialed number if, for example, the telephone call is answered, even if it subsequently drops; if the telephone call causes a telephone to ring at the dialed number but no one answers it; or if the telephone call is connected to a voicemail or other recorded message, even if it does not cause a telephone to ring and even if the debt collector is unable to leave a voicemail." A call that does not connect — a busy signal, a number not in service — is excluded by section 1006.14(b)(3)(ii) and does not count. That distinction lives in the dialer's disposition codes, not in the rule. Most platforms distinguish answered, answering-machine, no-answer, busy and SIT tones already; the question is whether the compliance count is built from those codes or from the number of records the campaign touched. Those two numbers are not the same, and the second one is not the regulatory one. Medium matters too. Comment 1006.14(b)-1 says that for purposes of 1006.14(b)(1) through (4), placing a telephone call "includes conveying a ringless voicemail but does not include sending an electronic message". A ringless voicemail campaign consumes the same seven calls a dialer does. An SMS campaign does not — though it is governed by other rules that this one has nothing to do with. ## Per debt, not per consumer Section 1006.14(b)(4) is the sentence that decides how the counter is keyed: "For purposes of this paragraph (b), particular debt means each of a consumer's debts in collection. However, in the case of student loan debts, the term particular debt means all student loan debts that a consumer owes or allegedly owes that were serviced under a single account number at the time the debts were obtained by a debt collector." The commentary works the arithmetic out in the open. Where a firm holds a medical debt and two credit card debts for the same consumer, "a debt collector may count an unanswered telephone call as one telephone call placed toward any one particular debt, even if the debt collector intended to discuss more than one particular debt had the telephone call resulted in a telephone conversation" — so twenty-one unanswered calls in seven days, allocated seven to each debt, still sits inside the presumption of compliance. That is what the rule permits. It is not advice about what a firm should do, and the next section explains why. The allocation only works if it is made and recorded at the time. An unanswered call that is not attributed to a debt when it is placed is a call that cannot be defended later, because the defence is the allocation. Conversely, a connected call in which the agent discusses two accounts counts against both: the commentary says a call in which the collector "initiates a conversation or leaves a voicemail about more than one particular debt" counts toward each such debt. ## The seven days after a conversation The second prong is the one that catches firms with otherwise-conservative dial plans. Section 1006.14(b)(2)(i)(B) bars placing a call to that person about that debt "Within a period of seven consecutive days after having had a telephone conversation with the person in connection with the collection of such debt. The date of the telephone conversation is the first day of the seven-consecutive-day period." It does not matter who called. The commentary provides that where a collector and a person discuss a particular debt, the collector has had a conversation in connection with that debt "regardless of which party initiated the discussion about the particular debt". An inbound call from a consumer asking a question starts the seven days exactly as an outbound contact does — which means a busy inbound line can quietly suppress an entire outbound campaign, and a firm that treats inbound and outbound as separate systems will not see it happen. The exclusion in section 1006.14(b)(3)(i) is the release valve, and it is narrow. Calls do not count if "Placed with such person's prior consent given directly to the debt collector and within a period no longer than seven consecutive days after receiving the prior consent, with the date the debt collector receives prior consent counting as the first day of the seven-consecutive-day period". The commentary adds that consent expires early when "the person consented to the additional telephone calls for a shorter time period and such time period has ended; (2) the person revokes such prior consent; or (3) the debt collector has a telephone conversation with the person regarding the particular debt." A consumer who says "call me Monday" has given you Monday, and the conversation on Monday spends the consent. ## The exclusions worth wiring in There are three, and they behave differently. Prior consent given directly to the collector, described above, is time-limited and self-cancelling. Calls "Not connected to the dialed number" are excluded outright by section 1006.14(b)(3)(ii) — this is the disposition-code exclusion, and it is the one most likely to be already available in the telephony data. Calls placed to the persons described in sections 1006.6(d)(1)(ii) through (vi) are excluded by section 1006.14(b)(3)(iii); those are the parties other than the consumer to whom a collector may communicate about the debt. A fourth situation is not framed as an exclusion but works like one. Comment 1006.14(b)(2)(i)-3 addresses a wrong number: once the collector learns the number is not that person's, "the telephone calls that the debt collector made to that number are not considered to have been telephone calls placed to that person". The counter has to be able to go backwards when a number is corrected, which is a data-model decision rather than a policy one. Every one of these is a subtraction from a number a regulator will otherwise read off the raw log. Each subtraction has to carry its reason in the record, because an unexplained gap between the telephony system's call count and the compliance count is the finding. ## Both presumptions are rebuttable This is the part that gets lost when the rule is reduced to "seven in seven". Staying under the line buys a presumption, not immunity. The commentary lists factors that may rebut the presumption of compliance, beginning with pattern: "The considerations relevant to this factor include whether the debt collector placed telephone calls to a person in rapid succession" — the illustrations given are two unanswered calls to the same number within five minutes, or seven calls to the same number within a single day. It also lists the content of prior communications, including a consumer who has said they do not owe the debt or do not want to be contacted about it, and the collector's own prior conduct. The presumption runs the other way too, and firms under-use it. Exceeding the frequency is presumed to be a violation, but the commentary identifies factors that may rebut that presumption — including whether the collector "placed a telephone call to comply with, or as required by, applicable law", and "Whether a debt collector placed a telephone call that was directly related to active litigation involving the collection of a particular debt." For a litigation firm, that second factor is not a footnote. A call to complete a court-ordered communication or to negotiate settlement of a pending suit is exactly the fact pattern the Bureau had in mind. Which means the useful artefact is not a count. It is a count plus a reason, per call, retained. A firm that can produce seven calls with no context has a presumption. A firm that can produce eight calls with the eighth tagged to a scheduled mediation has an argument. ## What an examiner asks The CFPB's debt collection examination procedures put the frequency question in the harassment module and phrase it as conduct first: the examiner is directed to "Determine whether the debt collector causes a person's telephone to ring or engages any person in telephone conversations repeatedly or continuously with intent to annoy, abuse, or harass", and then to test the two presumption thresholds. The order tells you what the exercise is. The numbers are a screen; the conduct is the subject. A bank running an oversight review of a placement portfolio asks a narrower version of the same thing, usually as a sample: give me the call history on these fifty accounts, per debt, with dispositions. The firm that can answer that from one query answers it in an afternoon. The firm that has to join a dialer export to a case management system by phone number answers it in three weeks and produces a reconciliation nobody trusts. ## What the log has to contain Reconstructing a 7-in-7 count after the fact requires four fields per call that many systems do not store together: the debt the call was placed against (not the consumer), the connection disposition, whether a conversation occurred, and the timestamp. Without the first, the count cannot be keyed correctly. Without the second, excluded calls cannot be subtracted. Without the third, the seven-day conversation bar cannot be applied at all. Regulation F does not require a firm to invent records it would not otherwise keep. Comment 1006.100(a)-2 says a collector "need not create and maintain additional records, for the sole purpose of evidencing compliance, that the debt collector would not have created in the ordinary course of its business". But it closes the obvious gap in the next breath: "However, if the debt collector maintains call logs, the call logs are evidence of compliance or noncompliance with the FDCPA and this part and the collector must retain them." Every firm running a dialer maintains call logs. The choice is not whether to have the evidence; it is whether the evidence is in a shape that answers the question. ## Primary sources 1. [12 CFR 1006.14(b)(2)(i)(A)](https://www.consumerfinance.gov/rules-policy/regulations/1006/14/) — The seven-call threshold (Consumer Financial Protection Bureau) > More than seven times within seven consecutive days; nor 1. [12 CFR 1006.14(b)(2)(i)(B)](https://www.consumerfinance.gov/rules-policy/regulations/1006/14/) — The seven days after a telephone conversation (Consumer Financial Protection Bureau) > Within a period of seven consecutive days after having had a telephone conversation with the person in connection with the collection of such debt. The date of the telephone conversation is the first day of the seven-consecutive-day period. 1. [12 CFR 1006.14(b)(2)(ii)](https://www.consumerfinance.gov/rules-policy/regulations/1006/14/) — The presumption of a violation above either threshold (Consumer Financial Protection Bureau) > a debt collector is presumed to violate paragraph (b)(1) of this section and FDCPA section 806(5) if the debt collector places a telephone call to a particular person in connection with the collection of a particular debt in excess of either of the telephone call frequencies described in paragraph (b)(2)(i) of this section. 1. [12 CFR 1006.14(b)(4)](https://www.consumerfinance.gov/rules-policy/regulations/1006/14/) — Particular debt — the counting unit, and the student loan exception (Consumer Financial Protection Bureau) > For purposes of this paragraph (b), particular debt means each of a consumer's debts in collection. However, in the case of student loan debts, the term particular debt means all student loan debts that a consumer owes or allegedly owes that were serviced under a single account number at the time the debts were obtained by a debt collector. 1. [Official Interpretations, comment 1006.14(b)-1](https://www.consumerfinance.gov/rules-policy/regulations/1006/14/) — Ringless voicemail is a call; an electronic message is not (Consumer Financial Protection Bureau) > includes conveying a ringless voicemail but does not include sending an electronic message 1. [Official Interpretations, comment 1006.14(b)(3)(ii)-1](https://www.consumerfinance.gov/rules-policy/regulations/1006/14/) — What connecting to the dialed number means (Consumer Financial Protection Bureau) > A debt collector's telephone call connects to the dialed number if, for example, the telephone call is answered, even if it subsequently drops; if the telephone call causes a telephone to ring at the dialed number but no one answers it; or if the telephone call is connected to a voicemail or other recorded message, even if it does not cause a telephone to ring and even if the debt collector is unable to leave a voicemail. 1. [12 CFR 1006.14(b)(3)(i)](https://www.consumerfinance.gov/rules-policy/regulations/1006/14/) — The prior-consent exclusion and its seven-day window (Consumer Financial Protection Bureau) > Placed with such person's prior consent given directly to the debt collector and within a period no longer than seven consecutive days after receiving the prior consent, with the date the debt collector receives prior consent counting as the first day of the seven-consecutive-day period 1. [Official Interpretations, comment 1006.14(b)(3)(i)-2](https://www.consumerfinance.gov/rules-policy/regulations/1006/14/) — How prior consent expires early (Consumer Financial Protection Bureau) > the person consented to the additional telephone calls for a shorter time period and such time period has ended; (2) the person revokes such prior consent; or (3) the debt collector has a telephone conversation with the person regarding the particular debt. 1. [Official Interpretations, comment 1006.14(b)(4)-1.ii](https://www.consumerfinance.gov/rules-policy/regulations/1006/14/) — The conversation bar does not depend on who called (Consumer Financial Protection Bureau) > regardless of which party initiated the discussion about the particular debt 1. [Official Interpretations, comment 1006.14(b)(4)-2.i](https://www.consumerfinance.gov/rules-policy/regulations/1006/14/) — Allocating an unanswered call to one debt (Consumer Financial Protection Bureau) > a debt collector may count an unanswered telephone call as one telephone call placed toward any one particular debt, even if the debt collector intended to discuss more than one particular debt had the telephone call resulted in a telephone conversation. 1. [Official Interpretations, comment 1006.14(b)(2)(i)-2.i](https://www.consumerfinance.gov/rules-policy/regulations/1006/14/) — Pattern as a factor rebutting the presumption of compliance (Consumer Financial Protection Bureau) > The considerations relevant to this factor include whether the debt collector placed telephone calls to a person in rapid succession 1. [Official Interpretations, comment 1006.14(b)(2)(ii)-2.ii](https://www.consumerfinance.gov/rules-policy/regulations/1006/14/) — Litigation-related calls as a factor rebutting the presumption of a violation (Consumer Financial Protection Bureau) > Whether a debt collector placed a telephone call that was directly related to active litigation involving the collection of a particular debt. 1. [Official Interpretations, comment 1006.14(b)(2)(ii)-2.i](https://www.consumerfinance.gov/rules-policy/regulations/1006/14/) — Calls made to comply with other law (Consumer Financial Protection Bureau) > Whether a debt collector placed a telephone call to comply with, or as required by, applicable law. 1. [Official Interpretations, comment 1006.14(b)(2)(i)-3](https://www.consumerfinance.gov/rules-policy/regulations/1006/14/) — Misdirected calls drop out of the count once the number is known to be wrong (Consumer Financial Protection Bureau) > the telephone calls that the debt collector made to that number are not considered to have been telephone calls placed to that person 1. [CFPB Examination Procedures — Debt Collection (March 2022), procedure 15](https://files.consumerfinance.gov/f/documents/cfpb_debt-collection-examination-procedures.pdf) — How the examiner frames the frequency question (Consumer Financial Protection Bureau) > Determine whether the debt collector causes a person's telephone to ring or engages any person in telephone conversations repeatedly or continuously with intent to annoy, abuse, or harass 1. [Official Interpretations, comment 1006.100(a)-2](https://www.consumerfinance.gov/rules-policy/regulations/1006/100/) — No duty to invent records, but call logs you keep must be retained (Consumer Financial Protection Bureau) > However, if the debt collector maintains call logs, the call logs are evidence of compliance or noncompliance with the FDCPA and this part and the collector must retain them. ## Related - [Call recording and retention for collections firms](https://ottoforfirms.com/guides/call-recording-retention/) — Consent before you record, the Regulation F retention rule and its three-year clock, and what a bank or a CFPB examiner is entitled to ask for. - [How to respond to a debt validation request](https://ottoforfirms.com/guides/responding-to-a-validation-request/) — What a written dispute inside the validation period actually stops, what verification has to contain, and when a firm may start collecting again. - [How banks audit their collection law firms](https://ottoforfirms.com/bank-audits/) — What regulators expect of banks supervising collection law firms, what an oversight review should examine, and where manual oversight fails. --- This is an informational reference, not legal advice, and using it creates no attorney-client relationship. Limitations periods turn on facts this page cannot know — which state's law governs, the contract type, when the claim accrued, and whether anything tolled or revived it. Confirm against the primary source and your own counsel before acting.