Lender compliance for direct borrower contact in N. Carolina

[Bob Malecki]

I saw this item on an email from my servicer and am concerned if we are violating any state regs for NC since we have loans in Charlotte and one of my VAs has been doing the consumer outreach for workouts. Our servicer is licensed in NC but we are doing the outreach directly for a loan mod. Any comments/perspectives or links to a website with clarity is appreciated. 

Specialty Loan Servicing No Collection program for non-performing Loans, is an offsite program where [servicer name] is the required compliant Servicer of Record, and the Lender pursues their own workouts including collection calls, loan modifications, foreclosures, Deed in Lieu, etc. FCI will attempt to transfer incoming Borrower calls directly to the Lender. It is the Lender’s responsibility to be aware of related State/Federal regulations, and keep [servicer name] appraised of Loan status changes. The Lender may not be able to use this program in certain states (NY, NC).

[Mike Hartzog]

My understanding is that NC requires a debt collector license to make contact with borrowers.  I know there are some servicers that won't board NC loans due to the difficulty in getting set up in that state.