The CFPB, jointly with the FTC, has filed an amicus brief with the U.S. Court of Appeals for the Third Circuit in Bock v. Pressler & Pressler, LLP, the case in which the district court ruled that a debt collection law firm violated the FDCPA by filing a complaint without “meaningful attorney involvement.” In the brief, the CFPB and FTC argue that the “meaningful attorney involvement” standard that has been applied to debt collection letters should apply equally to debt collection complaints.

The CFPB’s support for the plaintiff’s position in Bock is not surprising since the CFPB has sought to invoke the “meaningful attorney involvement” standard in its enforcement proceedings against collection firms. The Maryland Court of Special Appeals recently declined to adopt the standard for FDCPA claims based on alleged insufficient attorney involvement in debt collection litigation.