Q: If a call drops or is otherwise interrupted while a debt collector is leaving a limited-content message, is the voicemail still a limited-content message?
A: No. If a call drops or is otherwise interrupted and results in a partial voicemail that does not include all of the required content, that partial voicemail is not a limited-content message. 12 CFR § 1006.2(j).
As discussed in Debt Collection Limited-Content Messages Question 2
, if a voicemail contains information that conveys information about a debt, the voicemail is not a limited-content message and is a communication, even as a partial message. 12 CFR § 1006.2(d). If, however, a debt collector attempts to leave only a limited-content message, but the message is cut off, it is not a communication because the partial message does not contain information about a debt. For example, if the partial message contains only some of the required or optional limited-content message content, then the partial message is an attempt to communicate and not a communication.
Updated October 1, 2021