It is unlawful for any person, not only a debt collector, to design, compile and supply a form knowing that it will be used to make a consumer falsely believe that someone other than the creditor is participating in collecting the debt when that person is not. Flat-rating (selling letterhead or form letters to creditors for self-collection under a collector's name) is the classic case. Violators carry the same civil liability as debt collectors under section 813.
The graph holds this control, the 0 it maps to, and the evidence behind each claim, over MCP and REST.