State/Fed regs on contacting borrowers

[Bob Malecki]

This question popped up in a conversation I had with a fellow note buyer today. We are buying 1st position NPLs mainly in the southeastern US and all loans are boarded with FCI who has the proper licensing required. I'm having my assistant send out a "your options" letter and making phone calls to the borrowers in an attempt to do a loan mod and keep them in their home. FCI is handling the TILA requirements, statements, etc. Is there any violation of state or fed consumer protection regs by having my company contacting the borrower directly since we are not a licensed entity?