[harrumph]

>Fair enough, but it seems arbitrary and capricious

In the current context of super-widespread collections abuse, I'd say such a suggestion is anything but arbitrary.

> it requires a specialized body of skill and knowledge that many businesses would rather not have to develop in-house.

If that specialization and skill was a real thing, then we wouldn't see widespread abuse committed by the agencies like we do today. After all, virtually every abuse involves inaccuracy on the part of the agency.