Short answer
By checking each state's attorney exemption against what the firm actually does. Many states exempt licensed attorneys collecting within their law practice, but the exemption often stops when collection becomes the firm's primary business, when non-attorney staff do the collecting, or when the firm collects in states where its lawyers are not admitted. Firms that operate like agencies frequently need agency licenses.
The attorney exemption is narrower than most firms assume. States wrote it for lawyers collecting incidentally to legal practice, and several apply factors like the share of revenue from collections, the volume of demand letters, and who actually contacts consumers. A firm running a collection floor staffed by non-attorneys, or taking placements in states where no firm attorney is admitted, can be a collection agency in those states regardless of the letterhead, which means licensing and often a bond.
The multi-jurisdiction answer is an exemption-by-state analysis matched to the firm's real operating model, revisited when the model changes. Cornerstone is the U.S. licensing operating partner for lenders, mortgage companies, money services businesses, and accounts receivable management firms, and runs this analysis for collections firms so the exemption question is settled state by state instead of assumed nationally.
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