It is an initial communication with the consumer regarding their collection on a debt.
It is not required to include the dunning notice provisions. However, it triggers the requiremnt to send dunning notice within 5 days of that initial communication with the consumer. Thus, a violation would occur should you not receive dunning notice that was sent within the five day statutory period.
Lack of timely dunning notice is a violation, which you can separately deal with by way of complaint to the CFPB, but it is secondary, and does not in and of itself triggger a specific sanction.
If the consumer is awar of their rights, lack of dunning notice can actually be a procedural benefit in that any DV would be timely until they first provide dunning notice and its statement of the 30-day period for sending a timely DV.
Any DV request you send at this point would thus be timely, and impose a cease collection bar on the debt collector.
Whether or not you wish to send a DV is another matter.
If you dont recognize the debt as legitimate, you normally would not want to pay the debt.
However, sending a DV does not impose any time period in which they must validate, so you can be in limbo for an unspecified period, during which the debt collector would be barred from conducting any payment negotiations with you.
If immediate satisfaction is your primary goal, which might be the case if you were in a mortgage app process, then you might wish to forgo a DV and move directly to a PFD or settlement offer.
