Call center software for fintech collections: predictive dialer compliance guide

Last updated 2026-07-09

Why does predictive dialer compliance matter so much for fintech collections?

Each non-compliant call is its own violation. That is the whole problem in one sentence. Under 47 U.S.C. § 227, the Telephone Consumer Protection Act, a single unauthorized autodialed call to a cell phone carries a statutory penalty of $500, or $1,500 if a court finds the violation willful ^[1]. Fintech lenders and debt collectors often run campaigns with tens of thousands of calls per week. The math gets ugly fast.

Collections is exposed in a way marketing is not. You are, by definition, calling people who may not want to hear from you. Courts have repeatedly held that prior consent to receive marketing calls does not equal consent to receive debt collection calls using an autodialer ^[2]. Three things decide your risk: the loan application consent language, the purpose of the call, and whether your dialer qualifies as an automatic telephone dialing system (ATDS) under the current FCC interpretation.

Then layer the Fair Debt Collection Practices Act (FDCPA) on top. The FDCPA prohibits calling before 8 a.m. or after 9 p.m. local time, prohibits repeated calls intended to annoy, and limits contact attempts after a consumer sends a written cease-and-desist ^[3]. A predictive dialer that is not configured correctly can break both statutes in a single campaign.

Here is the twist that trips up fintech teams. If you are collecting on loans you originated, the FDCPA's first-party creditor exemption may protect you from FDCPA liability. It does nothing for your TCPA exposure. You can be exempt from one statute and fully liable under the other on the same call.

What is a predictive dialer and does it count as an ATDS under the TCPA?

A predictive dialer runs an algorithm that dials multiple numbers at once, predicts when an agent will be free, and connects live calls to available agents while dropping or leaving silence on calls where no agent is ready. The point is talk time. Predictive mode typically targets 40 to 55 minutes of live conversation per agent per hour, versus roughly 15 to 20 minutes on manual dialing.

Whether that system is an ATDS is the most litigated question in this space. The statute defines an ATDS as equipment with "the capacity to store or produce telephone numbers to be called, using a random or sequential number generator, and to dial such numbers" ^[1]. The Supreme Court's 2021 ruling in Facebook, Inc. v. Duguid narrowed that definition, holding that a device must use a random or sequential number generator to store or produce numbers to qualify ^[4]. That ruling gave some vendors room to argue their systems are not ATDSs because they call from uploaded lists, not randomly generated numbers.

Reality is messier than the headline. Many predictive dialers have multiple modes. A system dialing from a fixed list of customer numbers might survive Duguid scrutiny. The same system switched to a predictive or auto-blend mode that generates call sequences algorithmically might not. District courts are still sorting this out, and the FCC has signaled it may revisit the ATDS definition through rulemaking ^[5].

My advice is simple. Assume your predictive dialer is an ATDS. Build your consent framework accordingly, and document that assumption in writing. You can always argue the point in litigation. You cannot go back and get retroactive consent.

For teams running SMS alongside voice, the ATDS question hits text campaigns too. See our overview of tcpa sms compliance for how those rules map to text outreach.

What consent does a fintech collections team need before predictive dialing?

The TCPA requires "prior express consent" to call a cell phone using an ATDS or prerecorded voice ^[1]. For purely informational calls (payment reminders, account alerts), that standard applies. For calls with any marketing or solicitation element, the higher bar of "prior express written consent" kicks in. That means a written agreement, a clear disclosure that autodialed calls may result, and the consumer's signature (electronic counts) ^[5].

Debt collection calls sit in a gray zone. Courts have generally treated them as informational rather than marketing, so prior express consent is the operative standard. Consent still has to be specific. The FCC's 2012 order held that consent must be given to the entity making the call and cannot be buried in a general terms-of-service agreement without a clear disclosure about autodialed contact ^[5].

Put the ATDS consent language in the loan application itself. Keep it separate from other terms, with a checkbox the borrower has to select. Language like this works: "By checking this box, you consent to being contacted by [Company] at the phone number provided, including by autodialed calls or text messages, even if the number is a mobile number." Retain it, time-stamp it, and tie it to the account record.

Buying leads or accounts? Consent does not ride along with the file. The FCC's one-to-one consent rule that took effect in 2025 requires consent to name the specific seller making contact, which means purchased-lead consent is essentially worthless for ATDS calls unless the consumer consented to your company by name ^[5]. For fintechs buying debt portfolios, that is a real gap, not a technicality.

Building out your consent records? A structured sms opt in form process covers the written consent requirement for text and adapts cleanly to voice disclosures.

Which federal and state DNC rules apply to fintech collections calls?

The National Do Not Call Registry, maintained by the FTC, covers telemarketing calls, not pure debt collection ^[6]. But if your collection calls carry any marketing component, like offering refinance options or new products mid-call, the registry rules apply and you must scrub against it every 31 days at minimum.

The TCPA's own do-not-call provisions reach further. Once a consumer tells you to stop, you have to honor that request within 30 days, keep an internal DNC list, and honor the request for at least five years ^[1].

State rules pile on. Florida's Mini-TCPA (Florida Telephone Solicitation Act, FTSA), effective July 2021, created a private right of action for autodialed calls or texts made without prior express written consent, and it reaches any call or text to a Florida area code ^[7]. Texas, Oklahoma, and several other states have passed similar statutes. California's Rosenthal Fair Debt Collection Practices Act extends FDCPA-style protections to first-party creditors that federal law would otherwise exempt ^[8].

A dialer that only scrubs the federal registry is not enough for a fintech operating nationally. You need state-specific DNC scrubbing, time-zone-aware call windows, and a system that tracks and enforces opt-outs across channels.

Jurisdiction	Rule	Key threshold
Federal TCPA	Prior express consent for ATDS calls	$500-$1,500 per call [1]
FTC National DNC	Scrub every 31 days for telemarketing	$51,744 per violation [6]
Florida FTSA	Prior express written consent, private right of action	$500-$1,500 per call [7]
California Rosenthal Act	FDCPA rules apply to 1st-party collectors	Actual damages + $1,000 per violation [8]
FDCPA (3rd-party collectors)	8am-9pm local, cease-and-desist honoring	$1,000 per action + class liability [3]

What call center software features does a fintech collections team actually need for TCPA compliance?

Ask about specifics before you sign. A lot of vendors market compliance features that are either shallow or shipped turned off by default. Here is the list I would run through line by line.

Real-time DNC scrubbing. The platform should scrub numbers against the National DNC Registry, your internal DNC list, and any state lists right before the call goes out, not at upload. Numbers change status. A scrub done at import that is 45 days old is a liability sitting in your dialer.

Time-zone detection and call-window enforcement. The system should look up every number's local time zone and hard-block calls outside 8 a.m. to 9 p.m. local. This is a hard stop, not a soft warning. Some platforms default to the server's time zone, which is how teams accidentally call the East Coast at 9:30 p.m.

Abandonment rate controls. The FTC's Telemarketing Sales Rule requires predictive dialers to connect calls to a live agent within two seconds of the person answering, and it caps call abandonment at 3 percent per campaign per 30 days ^[9]. Your software needs to track and enforce this. Calls that hit a dead line, silence, or a prerecorded message instead of a live agent count toward that 3 percent.

Consent documentation and retrieval. Each outbound record should link to the consent proof for that consumer's account. When a demand letter lands, you need to pull that record in minutes, not days.

Call recording and archiving. Most collections programs require recording. Look for configurable state-based recording consent prompts, because California, Florida, and about a dozen other states require all-party consent to record ^[8].

Revocation and opt-out management. When a consumer says stop on a live call, the system should flag that account and pull it from active queues automatically. Manual opt-out processes leak. The platform should also accept opt-outs from other channels and sync them to the dialing list.

Manner-of-contact controls. If consumers can pick calls, texts, or email for account communications, that preference data needs to flow into the dialer and suppress the channels they declined.

LeadCompliant's free TCPA compliance checker helps you audit whether your current stack handles the DNC scrubbing and consent verification pieces before you switch platforms.

How should fintech teams handle ATDS risk when using predictive vs. preview vs. power dialers?

Not every dialer carries the same ATDS risk. Match the tool to the campaign and you can cut your exposure without killing throughput.

A preview dialer shows an agent a record and waits for a manual click to dial. The agent decides when to call and which number to use. This is the lowest ATDS risk because a human starts every call. It is also the slowest mode. Use it for high-value accounts, disputed accounts, or any call that needs prep before it connects.

A power dialer (also called a progressive dialer) automatically dials the next number the moment an agent wraps a call. One call per available agent, one at a time. No abandoned calls. ATDS risk is moderate and turns on the algorithmic-generation question courts are still working through post-Duguid.

A predictive dialer dials multiple numbers per agent, predicts availability, and tries to have a live person connected the second an agent frees up. Abandoned calls are baked in. ATDS risk is highest here. The upside is real: predictive mode can deliver two to three times the contact volume per agent-hour compared to preview. For high-volume, low-balance accounts where the economics demand efficiency, that tradeoff can be worth it if your consent is airtight.

The right setup for most fintech collections operations is a platform that supports all three modes and lets compliance rules, not productivity targets, decide which mode runs against which account segment. Segment the portfolio by consent quality and account value. Then match the dialing mode to the risk.

For how these rules apply to text campaigns running alongside voice, the tcpa overview covers the unified consent framework.

What FCC orders and court cases should fintech compliance teams know about?

A handful of decisions moved the ground under this industry. Know these cold.

Facebook, Inc. v. Duguid (2021). The Supreme Court held 9-0 that an ATDS must use a random or sequential number generator to store or produce numbers ^[4]. That narrowed the broad reading many lower courts had used and gave vendors room to argue their list-based systems fall outside the definition. It did not kill TCPA liability for list-based predictive dialers. It raised the plaintiff's burden.

Ayers v. Receivables Performance Management (2019, E.D. Mich.). A court found a debt collector violated the TCPA by calling a reassigned number where the prior subscriber had consented but the new subscriber had not ^[2]. Reassigned-number liability is a live problem for any team working older account data.

The FCC's Reassigned Numbers Database. The FCC launched a Reassigned Numbers Database (RND) that callers can query to check whether a number has been reassigned since consent was obtained ^[5]. Using the RND creates a safe harbor against liability for calls to reassigned numbers. If your dialer does not query the RND, you are exposed.

The FCC's 2025 one-to-one consent rule. This rule requires TCPA consent for marketing calls to name the seller who will be calling ^[5]. It ends the lead-generator model where one consent captured hundreds of sellers. For fintechs buying leads or debt portfolios, that is a major change to how you source callable accounts.

FTC telemarketing enforcement. The FTC has collected hundreds of millions in penalties across telemarketing enforcement actions, with abandoned-call-rate violations and DNC violations among the most common triggers ^[6]. The agency treats vendor "compliance software" claims with skepticism unless the actual practices match the marketing.

For ongoing developments, tcpa news today tracks FCC orders and major case outcomes as they land.

How do call time restrictions and abandoned call rules work in collections dialing?

The FDCPA sets the national floor: no calls before 8 a.m. or after 9 p.m. local time for the consumer ^[3]. The TCPA itself does not set call hours for debt collection, but some states tighten the window. Washington, for one, limits debt collection calls to 8 a.m. to 9 p.m. and restricts calls on Sundays and holidays under RCW 19.16.250.

Time-zone handling is where teams get burned. Say you dial a Florida consumer from a platform set to Pacific time. Your 3 p.m. call is 6 p.m. Eastern, which is fine. Your 6 p.m. call is 9 p.m. Eastern, right at the cutoff. Your 6:01 p.m. call is a violation. Set call windows per record using the consumer's area code or, better, a real-time geolocation lookup.

Abandoned-call rules under the FTC's Telemarketing Sales Rule apply when your call has a telemarketing component. An abandoned call is one where the consumer answers but no agent connects within two seconds of the greeting ^[9]. On an abandoned call you have to play a prerecorded identification message with your name, phone number, and a statement that no message will be left. The 3 percent cap is measured per campaign over 30 days.

Pure debt collection calls with no sales element generally fall outside the TSR's abandoned-call rules. Many fintech products blur that line. If your collections agent can offer a refinance or a new product during the call, the FTC will likely treat the whole campaign as telemarketing for TSR purposes, and the 3 percent cap applies.

What should fintech teams look for in a TCPA-compliant predictive dialer vendor contract?

The contract matters more than the sales deck. Nail these down in writing before you sign.

Who owns compliance configuration? Many platforms are compliant by design and non-compliant by default. Time-zone controls, DNC scrubbing frequency, abandonment caps, and call recording often ship turned off or set to permissive defaults. The contract should say who configures and maintains these controls, and you should get documentation of the correct settings.

Data indemnification. If the vendor's DNC scrubbing fails because their database went stale, does their indemnification clause cover your resulting liability? Most do not. You want a vendor that commits to current DNC data and indemnifies you for failures attributable to their data.

Consent data portability. If you switch vendors, can you export complete consent records with timestamps? Consent documentation is a litigation asset. Vendors who lock your consent data inside proprietary formats are a risk you carry into every future lawsuit.

Reassigned Numbers Database integration. Ask flat out: does the platform query the FCC's Reassigned Numbers Database on every call, or at list upload? Get the answer in writing. The safe harbor for reassigned-number liability requires you check the RND and receive a no-recent-reassignment response before calling ^[5].

Audit logs. You need immutable call records showing the number dialed, the time, the agent, the campaign, the result, and the DNC status at dial time. These logs are what you hand your attorney when a plaintiff's lawyer sends a litigation hold letter.

SLA for opt-out processing. If a consumer requests a stop on Monday, the system should be suppressing that number by Monday. Ask what the maximum opt-out processing delay is and get it into the SLA.

How do fintech teams build a compliance program around their dialing software?

Software is a tool inside a program, not the program itself. The companies that face catastrophic TCPA exposure almost always had the right features and either did not use them or let process gaps make the protections meaningless.

Start with a consent audit. Map every account segment to its consent documentation. For accounts where you cannot find valid, specific ATDS consent, restrict them to manual dialing or written communication until you get consent or resolve the account.

Write a dialing policy. One page. Specify which dialer modes are allowed for which account types, approved call hours, the target abandonment rate, who owns DNC scrubbing frequency, and who can override defaults and under what authority. Have legal or outside counsel review it.

Train agents on revocation. Every agent needs to know how to handle a consumer who says stop, and needs to process that request in real time inside the platform. Mystery shop it. Call your own lines, ask to stop being called, and watch what happens.

Run quarterly compliance reviews. Pull a sample of call records, verify DNC scrub dates, confirm opted-out numbers are suppressed, and check abandonment rates by campaign. Document the review. Find a gap, fix it, and document the fix.

Have a litigation response plan. Before the demand letter arrives, know who your TCPA defense counsel is, where your consent records live, how fast you can pull call logs, and what your indemnification position is with your vendor. Responding 30 days late because you could not find your records is expensive.

LeadCompliant's compliance kit includes consent documentation templates and a pre-call checklist built for outbound collections teams. It covers the fields most commonly requested in discovery.

Running lead generation alongside collections? lead generation compliance news covers how consent rules are shifting across both use cases.

What does a TCPA lawsuit in collections actually look like, and how much does it cost?

The plaintiffs' bar runs a specific playbook. A consumer gets an unwanted autodialed call. They hire a TCPA attorney, often on contingency. The attorney sends a demand letter, sometimes followed straight away by a federal lawsuit. Because the TCPA's $500-to-$1,500 statutory damages are per call and require no proof of actual harm, even a few dozen calls to an unconsented number can produce a six-figure demand.

Class actions are the real exposure. If an attorney certifies a class of consumers who all received unconsented calls, the math scales to company-threatening numbers. The 2023 settlement in Perez v. Rash Curtis & Associates, a debt collection TCPA case, resulted in a $28 million settlement covering a class of consumers who received autodialed calls without consent ^[10].

Defense costs for a single-plaintiff TCPA case typically run $50,000 to $150,000 in legal fees if it goes through discovery, even when you win. Settlement values for single-plaintiff cases often land in the $2,000 to $10,000 range, which is exactly why companies settle fast rather than fight winnable cases. That incentive structure lets plaintiff attorneys file volume suits against companies with weak consent documentation and collect small, consistent settlements.

The best defense is documentation. Courts have dismissed TCPA claims where the defendant produced clear, time-stamped consent records showing the specific plaintiff agreed to autodialed contact ^[2]. The cases that settle badly are the ones where the company cannot produce the consent record at all.

One more thing. Cyber liability and errors-and-omissions policies increasingly add TCPA exclusions. Do not assume your insurance covers TCPA class exposure. Read the policy language before you need it.

How should fintech collections teams handle reassigned and recycled phone numbers?

Reassigned numbers are one of the sneakiest traps in collections dialing. A consumer takes out a loan, gives you their cell number, consents to autodialed contact, then changes their phone number. The carrier reassigns that number to a new subscriber who never had any relationship with you. You keep calling because the number is still in the account file. The new subscriber, hearing about someone else's debt, has a TCPA claim against you.

The FCC launched the Reassigned Numbers Database in 2021 to close this gap. Callers query the RND with a phone number and a date, and the database returns whether the number has been permanently disconnected and reassigned since that date ^[5]. Query the RND, get a no-recent-reassignment response, and you have a safe harbor. Even if the number turns out to have been reassigned, reasonable reliance on the RND response shields you.

The RND is not free. As of 2024, access costs $0.002 per query with a monthly minimum, and volume pricing tiers exist ^[5]. For a team making 100,000 calls a month, that is roughly $200 in query costs. That is nothing next to the liability, but budget for it and build the API integration into your dialer workflow.

Number recycling is the related problem. Carriers are not required to wait before reassigning a disconnected number, and the FCC has noted numbers can be recycled in as little as 30 to 45 days. If your account data is more than 30 days old and you have not queried the RND, you have exposure.

The practical rule for collections teams: query the RND on every number at or just before dial time, not at list import. Flag any number the RND returns as potentially reassigned for manual review before anyone calls it.

Frequently asked questions

Can a fintech company that originates its own loans use a predictive dialer to collect on them?

Yes, but the TCPA still applies even though the FDCPA's first-party creditor exemption may shield you from some FDCPA claims. You still need prior express consent to use an ATDS to call a consumer's cell phone. The loan application is the right place to get that consent, with explicit autodialed-call disclosure language. Operating as a first-party creditor does not reduce your TCPA exposure.

What is the 3 percent abandoned call rule and does it apply to debt collection calls?

The FTC's Telemarketing Sales Rule limits abandoned calls to 3 percent of answered calls per campaign per 30-day period and requires connection to a live agent within two seconds of the consumer's greeting. It applies to telemarketing calls. Pure debt collection calls with no marketing element may not be covered, but if your agents can offer new products or refinancing during the call, the FTC is likely to treat it as telemarketing and apply the 3 percent cap.

Does the Facebook v. Duguid ruling mean predictive dialers are no longer covered by the TCPA?

No. Duguid narrowed the ATDS definition to systems that use a random or sequential number generator to store or produce numbers. Many predictive dialers can be argued outside that definition when calling from fixed lists. But courts are still litigating this at the district level, FCC rulemaking may revisit the question, and some dialer modes still carry ATDS risk. The conservative posture is to treat your dialer as an ATDS and keep strong consent records.

How often do we need to scrub our call list against the National DNC Registry?

For telemarketing calls, the FTC's Telemarketing Sales Rule requires scrubbing every 31 days. For pure debt collection calls without a marketing element, the National DNC Registry technically does not apply, but your internal DNC list must be maintained and honored. Many collections teams scrub against the national registry anyway to protect against campaigns that blur the telemarketing line.

What states have their own TCPA-like laws that affect collections dialers?

Florida's Telephone Solicitation Act (FTSA), effective July 2021, created a private right of action for autodialed calls without prior express written consent and covers any call to a Florida area code. California's Rosenthal Act extends FDCPA rules to first-party collectors. Texas, Oklahoma, and Washington have similar consumer protection statutes. A nationally operating fintech needs state-specific compliance review beyond federal TCPA coverage.

What is the FCC Reassigned Numbers Database and does my dialer need to query it?

The FCC's Reassigned Numbers Database lets callers check whether a phone number has been permanently disconnected and reassigned since a given date. Querying it and receiving a clean response creates a safe harbor against liability for calls to reassigned numbers. Most modern compliance-focused dialer platforms support RND API integration. If yours does not, that is a material gap. Query costs run approximately $0.002 per lookup as of 2024.

How does the FCC's 2025 one-to-one consent rule affect fintech collections?

The rule requires TCPA consent for marketing calls to specifically name the company making contact. For fintechs buying debt portfolios or leads, consent obtained by the originating lender or lead generator does not transfer to you for ATDS calls. You need consent that names your company. This makes purchased-debt collections by autodialer significantly riskier unless you can re-obtain consent or restrict to manual dialing.

Can we call consumers who have not explicitly consented if we have their number from the loan file?

Having a consumer's number does not equal having ATDS consent. Courts have held that giving a phone number during a transaction implies consent to be called about that transaction, but only if you use a non-ATDS method, or if the loan documents included explicit autodialed-call consent language. If your loan agreement did not include that disclosure, restrict those accounts to manual dialing or written outreach.

What should we do when a consumer tells an agent to stop calling during a live call?

The agent should acknowledge the request on the call, document it in real time in the CRM or dialer platform, and ensure the number is flagged for suppression before the next dial cycle. Under the TCPA, once a consumer revokes consent, you must stop ATDS calls. The FDCPA additionally requires honoring written cease-and-desist requests. Your platform should make real-time opt-out entry a one-click action, not a multi-step process.

What call recording rules apply to fintech collections calls?

Federal law and most states require only one-party consent to record a call, meaning one participant's awareness is enough. California, Florida, Illinois, Washington, and about a dozen other states require all-party consent. Your dialer should play a recording disclosure prompt on every call to consumers in all-party-consent states. Failing to do so exposes you to both state wiretapping liability and FDCPA claims about harassing contact practices.

How do we handle cell phone numbers versus landlines in our collections campaigns?

The TCPA's ATDS restrictions apply to calls to cell phones and residential lines. Calling a cell phone with an ATDS without consent is a TCPA violation. Calling a landline with an ATDS is generally not a TCPA violation for non-telemarketing calls, though prerecorded messages to residential landlines require consent. Your dialer should identify mobile versus landline status using a carrier lookup service and apply different rules accordingly.

What is a realistic budget for TCPA-compliant predictive dialer software for a small fintech team?

Pricing varies widely. Cloud-based predictive dialer platforms with built-in compliance features typically run $100 to $300 per agent seat per month for small teams. Add DNC scrubbing service costs ($50 to $200 per month depending on volume), RND query costs (roughly $0.002 per number), and call recording storage. A 10-agent team should budget $1,500 to $4,000 per month total for software and compliance data services before implementation and training.

Are there compliance differences between using a cloud dialer versus an on-premise system?

The TCPA does not distinguish between cloud and on-premise systems. The legal exposure is identical. Practically, cloud platforms tend to receive compliance feature updates (DNC database refreshes, RND integration, new state rules) more consistently than on-premise installs that require IT deployment for each update. For small fintech teams without dedicated IT, cloud platforms generally make it easier to stay current with regulatory changes.

Sources

1. U.S. Government Publishing Office, 47 U.S.C. § 227 (Telephone Consumer Protection Act): TCPA statutory penalties of $500 per violation, $1,500 for willful violations; ATDS definition; prior express consent requirement
2. Ayers v. Receivables Performance Management, E.D. Mich., No. 15-cv-13178 (2019): Court found debt collector violated TCPA by calling a reassigned number where prior subscriber had consented but new subscriber had not
3. Federal Trade Commission, Fair Debt Collection Practices Act (15 U.S.C. § 1692): FDCPA prohibits calls before 8 a.m. or after 9 p.m. local time, repeated harassing calls, and requires honoring written cease-and-desist requests
4. Supreme Court of the United States, Facebook, Inc. v. Duguid, 592 U.S. 395 (2021): Court held ATDS must use random or sequential number generator to store or produce numbers; narrowed TCPA ATDS definition
5. Federal Trade Commission, National Do Not Call Registry and Telemarketing Enforcement: National DNC Registry scrubbing requirement every 31 days; FTC civil penalty of $51,744 per violation; telemarketing enforcement totals
6. Florida Legislature, Florida Telephone Solicitation Act, F.S. § 501.059: Florida FTSA requires prior express written consent for autodialed calls; private right of action; $500-$1,500 per violation
7. California Department of Financial Protection and Innovation, Rosenthal Fair Debt Collection Practices Act (Cal. Civ. Code § 1788): California Rosenthal Act extends FDCPA rules to first-party creditors; all-party call recording consent requirement; actual damages plus $1,000 per violation
8. Federal Trade Commission, Telemarketing Sales Rule, 16 C.F.R. Part 310: TSR requires predictive dialers to connect to live agent within two seconds; maximum 3 percent abandoned call rate per campaign per 30-day period
9. Perez v. Rash Curtis & Associates, N.D. Cal., Case No. 4:16-cv-03396-YGR (2023 settlement): $28 million class action settlement for debt collector TCPA violations involving autodialed calls without consent