CFPB Supervision and a Charge-Off Sale: The $10 Million Test Still on the Books
The larger-participant test for consumer debt collection is still more than $10 million in annual receipts. A sale does not turn on that test.
Desk notes · Charged-off market
Operator notes from Triton Financial Solutions on buying and selling charged-off debt: data tapes, chain of title, FDCPA and Regulation F, forward flow, and 2026 secondary-market pricing. Written for institutional sellers and qualified buyers — not consumer collection advice.
The larger-participant test for consumer debt collection is still more than $10 million in annual receipts. A sale does not turn on that test.
A purchase passes title at funding. A placement leaves title with the creditor.
The box, the sample, the funding, and the collector path an operating company lines up first.
A score is usable when the tape says which score, and the date it was pulled.
What a small-dollar charge-off file has to show before anyone discusses a percent of face.