TrueAccord Wins Key TCPA Rulings on Debt Collection Text Messaging

3 min readSources: National Law Review

Two federal courts ruled TrueAccord’s debt collection texts comply with TCPA restrictions.

Why it matters: These rulings help legal teams understand when debt collection texts violate the TCPA. Clear guidance reduces litigation risk and informs compliant messaging strategies.

  • October 5, 2026: Maryland federal court in Nickson v. TrueAccord ruled debt collection calls aren’t marketing under TCPA Do-Not-Call provisions.
  • TrueAccord’s dialing system does not use a random or sequential number generator, so it isn’t an automatic telephone dialing system (ATDS) under TCPA.
  • February 19, 2026: Texas court in Robertson v. TrueAccord found personalized text messages mean no ATDS use, protecting TrueAccord from TCPA autodial claims.
  • Robertson also applied the mailbox rule, presuming emails are received upon sending, aiding defendants’ compliance arguments.

Two federal court rulings in 2026 affirmed that TrueAccord’s debt collection text messages comply with the Telephone Consumer Protection Act (TCPA), clarifying regulatory limits for legal teams handling text-based debt collection.

In Nickson v. TrueAccord Corp., the U.S. District Court for the District of Maryland ruled on October 5, 2026, that debt collection calls are not "marketing" under the TCPA's Do-Not-Call (DNC) provisions. This distinction means DNC rules simply do not apply to these calls.

The court examined TrueAccord’s dialing system and found it does not create or store telephone numbers nor use a random or sequential number generator—a key test for defining an automatic telephone dialing system (ATDS) under TCPA. The TCPA restricts calls made by ATDS to protect consumers from unwanted automated contacts. Since TrueAccord’s system doesn’t fit this definition, the court ruled it compliant.

Separately, on February 19, 2026, in Robertson v. TrueAccord Corp., the U.S. District Court for the Southern District of Texas addressed TCPA claims based on text messages. It found that the texts containing personalized details, including specific debt amounts, indicate absence of ATDS use. This protects TrueAccord from TCPA restrictions on autodialed communications.

The same court applied the "mailbox rule," a legal principle presuming emails are received once sent unless rebutted. This presumption helped TrueAccord defend against claims based on email receipt timing.

The Robertson court noted, "This conduct does not approach a level that would allow the Court to infer an intent to harass," reinforcing that debt collection texts with personalized content differ crucially from automated spam calls. Such clarifications aid legal teams evaluating TCPA compliance in outreach strategies.

Together, these decisions provide clearer legal precedent, signaling to general counsels and compliance officers that personalized, non-random dialed debt collection texts and emails generally avoid TCPA violations. This reduces litigation risks and supports lawful debt collection communications.

By the numbers:

  • October 5, 2026 — Maryland court ruling date in Nickson v. TrueAccord.
  • February 19, 2026 — Texas court ruling date in Robertson v. TrueAccord.
  • 2 federal courts — issued key TCPA compliance rulings related to TrueAccord's text messaging