I respectfully dissent. The majority does not explicitly find that the claims alleged by Mrs. Chassereau do not arise in any matter relating to her agreements with Global-Sun, yet nonetheless holds that the arbitration clause contained in the Installation Agreement does not require Mrs. Chassereau’s claims to be arbitrated.
We must decide whether Mrs. Chassereau’s claims arise in any manner or are related to her agreement with Global-Sun.3 Because I would hold that these claims qualify on both counts, I would reverse the decision of the court of appeals.
In examining whether an arbitration agreement extends to a particular tort claim, South Carolina courts must focus on the factual allegations supporting the claim to determine whether the allegations implicate the contractual agreement, regardless of the legal label assigned to the claim. See Am. Recovery Corp. v. Computerized Thermal Imaging, Inc., 96 F.3d 88, 93 (4th Cir.1996); Zabinski v. Bright Acres Assocs., 346 S.C. 580, 597, 553 S.E.2d 110, 118 (2001). We have held *174that a tort claim that does not arise under the governing contract is nevertheless required to be arbitrated if there is a “significant relationship” between the tort claim and the contract in which the arbitration clause is contained. Zabinski, 346 S.C. at 598, 553 S.E.2d at 119. Nothing relates more significantly to a contract than efforts to collect amounts due thereunder.
Case law from other jurisdictions supports this conclusion. In Green Tree Fin. Corp. v. Shoemaker, 775 So.2d 149 (Ala. 2000), the purchasers of a mobile home sued the company which financed the purchase. The purchasers claimed that after they became delinquent in their payments, the finance company began a systematic course of harassing them and invading their privacy. Id. at 150. Although the arbitration clause in Shoemaker was broader than the clause at issue in the instant case, the Alabama Supreme Court held:
The plain language of this provision requires the plaintiffs to submit to arbitration all controversies that arise from, or relate to, the contract. That language clearly encompasses the plaintiffs’ claim alleging invasion of privacy, a claim that arose out of the underlying business transaction of collecting delinquent monthly payments.
Id. at 151.4
The case of In re Conseco Fin. Servicing Corp., 19 S.W.3d 562 (Tex.Ct.App.2000), also arose out of a financed purchase of a mobile home. Interpreting whether an arbitration clause identical to the clause at issue in Shoemaker applied to virtually identical claims, the court held:
[The complaint] arises from Conseco’s alleged efforts to collect the amounts due under the terms of the agreement. Absent the contract, there would be no relationship between [the parties], and there would have been no debt collection. ... Therefore, we conclude that [the plaintiffs] claims based on Conseco’s acts in collecting the debt owed on the *175contract arise from or relate to the contract and so are within the scope of the arbitration clause.
Id. at 570.
I believe the reasoning of both Shoemaker and Conseco applies with equal force in the instant case. In my view, it is difficult to imagine something more related to a debt agreement than actions taken to collect the debt. Under any conceivable definition of the word “significant,” actions taken in seeking to collect a debt must be significantly related to the debt.
The rule the majority announces is troubling in several regards. Primarily, the rule is inconsistent with the notion that all doubts regarding the question of arbitration are to be construed in favor of arbitration. See Zabinski, 346 S.C. at 597, 553 S.E.2d at 118. Similarly, the rule runs afoul of the oft repeated notion that unless a court can say with positive assurance that the arbitration clause is not susceptible to any interpretation that covers the dispute, arbitration should generally be ordered. See id. Admittedly, these arbitration principles run counter to general notions of contract interpretation; namely, that a court will construe any doubts and ambiguities in an agreement against the drafter of the agreement. See Myrtle Beach Lumber Co., Inc. v. Willoughby, 276 S.C. 3, 8, 274 S.E.2d 423, 426 (1981) (citing 17A C.J.S. Contracts § 324). In contrast to the majority’s rule, however, the principle that doubts are construed in favor of arbitration is rooted in a statutory proscription. See Moses H. Cone Mem’l Hosp. v. Mercury Constr. Corp., 460 U.S. 1, 24, 103 S.Ct. 927, 74 L.Ed.2d 765 (1983) (stating that § 2 of the Federal Arbitration Act, 9 U.S.C. § 1, et seq., is a congressional declaration of a liberal federal policy favoring arbitration agreements, notwithstanding any state substantive or procedural policies to the contrary).
Mrs. Chassereau’s claims unquestionably arise out of and are significantly related to the Installation Agreement. Accordingly, I would reverse the decision of the Court of Appeals.
. This limitation of our inquiry is based on the fact that the arbitration agreement at issue provides that "any disputes arising in any manner relating to this agreement ... shall be subject to mandatory, exclusive and binding arbitration.” (emphasis added).
. The arbitration clause in Shoemaker purported to apply not only to all claims arising out of or relating to the agreement, but also to all claims between the parties. Id. at 150. This distinction is insignificant, however, because the court in Shoemaker rests its holding only on the relationships of the claims to the agreement. See id. at 151. Thus, Mrs. Chassereau’s attempt to distinguish Shoemaker on this ground is unpersuasive.