Why voicemail still matters: With iPhone features that screen or silence unknown callers (including Screen/Silence Unknown Callers and Live Voicemail with real-time transcription), a large share of first-attempt calls never ring through - your voicemail becomes the message the consumer actually sees. Done right, it’s both compliant and high-response.
Note: Recent iOS updates also highlight call-screening options in Settings, which increases the odds that unknown calls route to transcription or voicemail. That makes limited-content messages (LCMs) a smart, low-risk touch in your channel mix.
The Rule in One Minute (Reg F – “Limited-Content Message”)
Under CFPB Regulation F (12 CFR §1006.2), a Limited-Content Message (LCM) is a voicemail for a consumer that includes all required items, may include certain optional items, and includes nothing else. If you stick to the LCM recipe, the message is not a “communication” about a debt—reducing third-party disclosure risk.
Required content (all of these):
- The caller’s business name (that does not indicate debt collection),
- A natural person’s name the consumer can contact,
- A telephone number to return the call, and
- A request that the consumer reply.
Optional content (allowed, not required):
- Date/time of the message,
- Suggested reply windows,
- A salutation/greeting.
No other content is permitted.
Practical constraint: If your legal/DBA name plainly signals “debt collection,” you cannot use an LCM with that name. (Some states may also require use of a registered DBA; if that name implies collections, the message would no longer qualify as an LCM.)
What About “Thank you” or “Goodbye”?
Neither phrase is explicitly listed. CFPB’s definition allows a salutation/greeting; dictionaries differ on whether “thank you” fits. Given ambiguity, many compliance teams avoid “thank you” and “goodbye” in LCMs for now. If you use them, treat “thank you” as part of a brief greeting—never an add-on that could be construed as extra content. (When in doubt, omit.)
Compliant LCM Templates
Short form (baseline):
“Hello, this is Daniel calling from ABC Solutions. Please call John Smith at 1-800-123-4567.”
Long form (with optional items):
“Hello, this is Daniel from ABC Solutions. It’s 3:00 p.m. on Monday, September 29. Please call my colleague John Smith at 1-800-123-4567. He’s available 8:00 a.m. to 6:00 p.m. Eastern, Monday–Friday.”
Non-compliant examples (do not use):
- “Hi, this is Daniel from Speedy Debt Collections Inc. Please call John Smith at 1-800-123-4567.” (Business name indicates collections.)
- “Good morning, this is Daniel from ABC Solutions. We’re trying to reach your cousin David. Please ask him to call John Smith at 1-800-123-4567.” (Third-party disclosure.)
- “Hi, I’m calling from ABC Solutions. Please give us a call back 1-800-123-4567.” (Missing natural person’s name and explicit request to reply to that person.)
Agent Cheat-Sheet
Always include (for LCM):
- Non-collections business name
- Natural person’s name
- Callback number
- Clear request to reply
You may include:
- Date/time of message
- Availability window
- Brief greeting
Never include:
- Amounts, balances, account details, or that you’re a debt collector
- Third-party references (“we’re trying to reach your cousin…”)
- Extra niceties that add content beyond a greeting (when in doubt, leave it out)
Disclaimer
The information provided by Krew (“we,” “our,” or “us”) in connection with our software, blog posts, and related materials is for general informational purposes only. It does not constitute legal, regulatory, or other professional advice. You should not act or rely on this information without obtaining professional advice tailored to your situation. Please consult qualified legal counsel for guidance.
