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2024 Consumer Financial Services Year in Review and A Look Ahead

We are pleased to share our annual review of regulatory and legal developments in the consumer financial services industry. With active federal and state legislatures, consumer financial services providers faced a challenging...more

Consumer Financial Services 2023 Year in Review and A Look Ahead

We are pleased to share our annual review of regulatory and legal developments in the consumer financial services industry. With active federal and state legislatures, consumer financial services providers faced a challenging...more

$225,000 Punitive Damages Award Upheld Where Creditor Repeatedly Contacted Customer After Being Notified of Attorney...

Earlier this year, a district court for the Middle District of Florida upheld a jury award of $225,000 in punitive damages in a debt collection case finding the defendant’s conduct “reprehensible” based on the physical harm...more

Connecticut Banking Regulator Reduces Fine Against Defunct Collection Firm

The Connecticut Banking Commissioner (Commissioner), acting through the Consumer Credit Division of the Department of Banking (the Division), conducted an investigation into the Law Offices of David M. Katz, discovering that...more

FCRA Claim for “Misleading” Double-Reporting of Debt by Original Creditor and Collection Agency Survives Motion to Dismiss

In Hansen v. Mountain America Federal Credit Union, the plaintiff became delinquent on a credit card account with her credit union. The credit union then assigned the debt to a third-party collection agency. Following the...more

Washington Federal Court Holds “Vague” and “Conclusory” References to “Reasonable Procedures” Not Enough to Establish FDCPA’s Bona...

In Gebreseralse v. Columbia Debt Recovery, LLC, the plaintiff, a tenant under a residential lease agreement, vacated the premises early due to concerns over the property’s condition. In response, the property management...more

Arizona Federal Court Holds FDCPA’s $1,000 Statutory Damages Provision Applies Separately to Each Defendant

In Casillas v. Thunderbird Collections Specialists Incorporated, et al., the plaintiff sustained a work-related injury requiring medical treatment for which a worker’s compensation claim was filed. Under state law, an injured...more

“Minor Procedural Missteps” in Collection Litigation Do Not Violate the FDCPA, District Court Holds

In Ingersoll v. Brandsness, the suit arose out of an effort by a collection agency and its counsel to obtain a judgment on unpaid medical bills. After the filing of the complaint, and the consumer’s filing an answer, the...more

NY AG Sues Digital Asset Exchange CoinEx for Failing to Register as Broker-Dealer

On February 22, New York Attorney General Letitia James filed an enforcement action against digital asset exchange, CoinEx, for failing to register as a securities and commodities broker-dealer and for falsely representing...more

Federal Regulators Jointly Release New FDCPA Examination Procedures

On Dec. 15, 2022, the Federal Financial Institutions Examination Council’s (FFIEC) Task Force on Consumer Compliance adopted revised examination procedures for the Fair Debt Collection Practices Act (FDCPA) and its...more

Filing Motion to Dismiss in State Court Waived Right to Removal, Holds Fourth Circuit

FIA Card Services, NA (FIA) obtained a default judgment in a collection action against Jerome Redman in West Virginia state court. FIA, through its counsel Javitch Block LLC (Javitch), then filed a wage garnishment action...more

Eleventh Circuit Holds TILA-Required Mortgage Statements Can Violate FDCPA

When mortgage servicers use periodic statements sent under the Truth in Lending Act (TILA) to collect a debt, they can be held liable under the Fair Debt Collection Practices Act (FDCPA) for any misleading or unconscionable...more

NY District Court Rules Consumer With No Intent to Pay a Debt Lacks Standing in FDCPA Claim for Conflicting Collection Letters

A consumer made charges on a credit card account, which she failed to pay as agreed. The creditor referred the account to a law firm, which served the consumer with a collection suit and obtained a default judgment for the...more

Continued Collection Activity Following Unsubstantiated Identity Theft Claim Does Not Violate FDCPA

In Blackmon v. Ad Astra Recovery Services, an individual claiming to be Brittney Blackmon obtained a payday loan in her name and then never made a payment. The debt was subsequently assigned to defendant collection firm Ad...more

Court: “Confusion, Stress, Concern, and Fear” Alone Are Not Enough to Create Concrete Injury Under FDCPA

The plaintiff, an individual consumer, filed a chapter 7 bankruptcy petition, including in his schedules a debt for past-due rent for a former apartment. The bankruptcy was a matter of public record and was listed on his...more

State AGs Endorse Call for President Biden to Cancel $50,000 in Federal Student Loan Debt

Last week, attorneys general from 17 states wrote a letter to Democrat and Republican leaders in both houses of Congress, expressing support for Senate Resolution 46 and House Resolution 100, which call upon President Biden...more

Declaration by Credit Card Company Regarding Vendor’s Mailing of Card Agreement Insufficient to Enforce Arbitration Provision...

A recent decision by the U.S. District Court for the District of Columbia underscores the significance of issues of proof when trying to enforce arbitration agreements. The case is Proctor v. First Premier Corp., No....more

Dunning Letter Contents Viewable through Envelope Window Are Subject to FDCPA, Holds Sixth Circuit

In a new decision slated for publication, the Sixth Circuit weighed in on an issue under the Fair Debt Collection Practices Act (FDCPA): whether a “benign language” exception exists to a flat prohibition of substantive...more

Court Rejects FDCPA Claims Based on Multiple Addresses, Validation Periods in Consecutive Collection Letters

In Paul v. Enhanced Recovery Company, the plaintiff received two letters from a debt collector concerning the same debt, about 40 days apart. The letters were identical, except for the dates and the amount of the settlement...more

Eleventh Circuit Weighs in on FCRA “Legitimate Business Purpose,” Affirms Dismissal in Favor of Defendant Who Accessed Credit...

In 2011 and 2013, Peri Domante’s personal information was stolen and fraudulently used to open two accounts with Dish Networks, LLC (“Dish”), a provider of television services. After being alerted to the fraud, Domante sued...more

Debt Collector Cannot “Outsource” Statutory Duty to Avoid Errors under FDCPA, Ninth Circuit Holds.

The plaintiff incurred a debt to a medical provider who placed the debt with a debt collector. The collection letter from the debt collector included a request for repayment of principal and interest. The plaintiff filed a...more

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