CFPB Validation Letters

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Real-World Example

ABC Collections uploads a new placement file using Add New Accounts + Generate CFPB Reg F Letters. The system validates the file, creates valid consumer accounts, and makes the completed upload available in Communications -> CFPB Validation Letters. ABC Collections can download the source CSV, download printable CFPB letters for active consumers, or send secure CFPB EcoLetters. The PDF letters and secure EcoLetter records are created when the creditor user takes one of those actions; importing the file should not automatically send letters. If ABC Collections sends secure EcoLetters, EcoLetter fees are deducted first and the system queues delivery work for active consumers. If ABC Collections downloads letters for print, any QR code must route the consumer through secure authentication before showing digital letter content.

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Visual Flow

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Overview

The CFPB requires collection agencies and law firms to make a Regulation F validation letter available when new accounts are placed for collection. This page covers two related steps:

• CFPB-capable upload batch management.
• Delivery after generation.

Import processing and delivery must remain separate. The Add + CFPB import creates the account batch that can produce CFPB letters, but delivery happens only when the creditor user selects a delivery method and any delivery requirements are satisfied.

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Generation And Management

When a creditor uploads accounts using Add New Accounts + Generate CFPB Reg F Letters, the system validates the file, creates active consumer accounts for valid rows, and makes the completed file available on the CFPB Letters page. The page shows pending CFPB files before any CFPB action is taken. After the creditor downloads letters or sends secure EcoLetters, the file moves into CFPB Communication History with the latest action snapshot. Each CFPB-capable file is tied to:

• Creditor.
• Upload history.
• Active consumer accounts.
• Uploaded user or SFTP source.
• Last CFPB action metadata when available.

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Generation Flow

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Generation Rules

• Only completed Add + CFPB uploads with active consumers should appear on the CFPB Letters page.
• Inactive consumers should not be included in CFPB letter counts.
• Printable CFPB PDFs render dynamically from active consumer account data.
• Downloading the source CSV should not create CFPB communication history.
• Downloading letters or sending secure EcoLetters should store the latest CFPB communication snapshot.
• Import completion does not trigger delivery.
• Creditor users must not access CFPB files from another creditor company.

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CFPB Eco Letter Delivery

Once an Add + CFPB file is available, creditors can act on active consumers by:

1. Secure EcoLetters.
2. Download & Print.

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Delivery Flow

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Secure EcoLetters

When a creditor user selects Send Secure EcoLetters:

• EcoLetter fees are deducted upfront from the creditor company’s membership balance or billing path.
• The system queues secure EcoLetter processing for active consumers in the file.
• The job creates a CFPB e-letter record with or without QR code.
• The job attaches the e-letter to each active consumer.
• The job triggers CFPB validation-letter delivery communications.
• The job schedules any needed delivered and not-opened follow-up communications.

Consumers must authenticate using last name, last four digits of SSN, and date of birth before accessing the secure digital letter. If authentication fails, access is denied. Delivery tracking should record:

• Delivery status.
• Sent timestamp.
• Authentication activity.
• Engagement activity.

This activity should be available in Campaign Tracker.

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Download And Print

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With QR Code

• This is the default option when the creditor opens the CFPB action modal.
• Includes a secure QR code linking to eco-portal login.
• Consumer must authenticate before accessing the letter.
• Enables digital engagement from mailed letters.
• QR codes must not expose sensitive data.

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Without QR Code

• Standard printable version.
• No digital access.
• No additional cost.

If the file contains more than 100 active consumers, printable letters are generated asynchronously as a ZIP package and a download link is sent to the configured company email.

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How It Should Work

• Completed Add + CFPB uploads with active consumers should appear in the pending CFPB list.
• CFPB PDF letters should render from the correct creditor and active consumer account data.
• Download & Print should support QR and non-QR versions.
• More than 100 printable letters should be generated asynchronously and emailed as a ZIP link.
• Secure EcoLetters should deduct EcoLetter fees before queueing delivery.
• Secure EcoLetters should create CFPB e-letter records for active consumers.
• CFPB actions should update CFPB Communication History with action type, action date, consumer count, QR choice, and cost.
• Only active consumers should count toward CFPB actions.
• Identity matching is required before secure consumer access.
• Letters must only be delivered to the correct consumer.
• Delivery and engagement must be tracked.

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How It Should Not Work

• It should not generate letters for invalid records.
• It should not mix creditor data across letters.
• It should not trigger delivery during generation.
• It should not send secure EcoLetters when EcoLetter fee deduction fails.
• It should not include inactive consumers in CFPB letter counts.
• It should not let a creditor user access another creditor company’s CFPB file.
• It should not expose letters to the wrong consumer.
• It should not ignore communication preferences or opt-outs.
• It should not expose sensitive data in QR codes.

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Developer Notes

• Add + CFPB import processing must complete before the file appears on the CFPB Letters page.
• Pending CFPB visibility should include only completed Add + CFPB uploads with active consumers and no prior CFPB action.
• CFPB Communication History should include only completed Add + CFPB uploads with a recorded CFPB action.
• The latest CFPB action snapshot should be stored on the upload history record.
• Downloading the source CSV should not move a file into CFPB Communication History.
• Printable letter downloads should render immediately for 100 or fewer active consumers and queue ZIP generation for larger files.
• Secure EcoLetter delivery should apply EcoLetter deduction before queueing delivery.
• Secure delivery requires exact identity match: last name, SSN4, and date of birth.
• Delivery and access events should be logged.
• Campaign Tracker must reflect sent, pending, failed, and viewed states.
• Temporary CFPB ZIP files are cleaned up by the scheduled cleanup command.

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Related App Areas

• routes/creditor/index.php
• app/Livewire/Creditor/Communications
• app/Livewire/Creditor/CFPBRegisterPage.php
• app/Console/Commands/RunCampaignCommand.php
• app/Jobs/SendCampaignEmailSmsOrELetterJob.php
• app/Jobs/ConsumersDownloadCFPBRegisterLetter.php
• app/Jobs/SendSecureEcoLettersJob.php
• app/Console/Commands/DeleteCFPBLettersZipFileCommand.php