2 DEBT COLLECTION RULE: DISCLOSING THE VALIDATION INFORMATION VERSION 1.0 (10/2021)
ITEMIZATION TABLE
uses one of these options also obtains a safe harbor for the content and format requirements
related to the validation information, except with respect to any content that appears on a separate
page. 12 CFR 1006.34(d)(2); see also 12 CFR 1006.34(c) and 34(d)(1).
However, because use of the model validation notice is not required, a debt collector also has the
option to provide the validation information using a form that is not substantially similar to the
model validation notice. Such a validation notice must still provide all of the required validation
information, and a debt collector who uses such a notice does not receive a safe harbor for the
content and format requirements of the Rule for the validation information provided. 12
CFR 1006.34(d)(2); see also 12 CFR 1006.34(c) and 34(d)(1).
2
This guidance document addresses how to provide certain validation information. This document
assumes use of the model validation notice.
3
Specifically, the Rule requires debt collectors to
include on the validation notice both the current amount of the debt and certain information about
the debt as of a particular date called the “itemization date.” Most of this required information
appears on the model validation notice in a tabular format.
Because this document assumes use of the model validation notice, it also assumes this
information will be disclosed in the tabular format. This document refers to that table as the
“Itemization Table” when providing guidance on the included disclosures. However, the concepts
discussed also apply more generally even if the model validation notice is not used.
2
More information about the validation information content and format requirements can be found in Section 12 of the
Debt Collection Rule Small Entity Compliance Guide
. Additionally, more information about the option to use the
model validation notice and how changes to the model validation notice affect the safe harbor for the validation
information content and format requirements can be found in the
Debt Collection Rule FAQs, Validation Information
Questions 2 through 4, as well as Section 12.1.3 of the Debt Collection Rule Small Entity Compliance Guide.
3
That is, this guidance document assumes a debt collector will use the model validation notice as it appears in
Appendix B of the Rule. This generally assumes that, among other things, a debt collector will not disclose certain
Itemization Table information on a separate page or use, for residential mortgage debt, the ability to substitute the
most recent periodic statement for some Itemization Table information (i.e., follow the special rule for residential
mortgage debt, or “Special Rule”). 12 CFR 1006.34(d)(2)(ii). As noted, a debt collector who uses either such option
retains the safe harbor for content and format requirements when using the model validation notice, except with
respect to content appearing on the separate page. However, some of the guidance discussed below may not apply, or
may apply differently, in such cases. For more information on the ability to disclose certain Itemization Table
information on a separate page, see footnote 8, below. For more information on the special rule for residential
mortgage debt, see footnotes 4 and 7, below and the
Debt Collection Rule FAQs, Validation Information: Residential
Mortgage Debt Questions.