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I am going to send out a round of DV's today. These are all past SOL for Oklahoma. Is it absolutely necessary to send them CMRR? Since it's not timely because they are so old already.
No, if the debt collector sent dunning notice more than 30 days ago.
An untimely DV invokes no cease collection bar against the debt collector, so becomes simply an informal request for verification.
They would have no requirment to respond or to cease their normal collection activities.
There is no real need, other than peace of mind in knowing they received it, to have legal documentation of their date or receipt.