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Fair Debt Collection Practices Act Debt Buyers Debt Collectors

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Indiana Appeals Court Rules That a Passive Debt Buyer Is a Debt Collector under the FDCPA and State Law

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The Court of Appeals of Indiana recently upheld a lower court’s decision that a debt buyer who purchased a portfolio of defaulted student loans and placed an account with a collection agency qualifies as a “debt collector”...more

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Judge Dismisses FDCPA Case Alleging Violations Based on Undated Model Validation Notice

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On November 20, a judge for the Southern District of New York granted a motion to dismiss a Fair Debt Collection Practices Act (FDCPA) class-action holding that a simple lack of a date on a model validation notice did not...more

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Citing Recent Precedent, Third Circuit Finds Plaintiff Lacks Standing Based on Informational Injury Doctrine in FDCPA Class Action

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On November 22, the Third Circuit Court of Appeals issued a decision finding that the plaintiff lacked Article III standing in a putative class action brought under the Fair Debt Collection Practices Act (FDCPA)....more

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Illinois Federal District Court Grants Summary Judgment Holding Use of a Local Area Code by a Non-Local Debt Collector Does Not...

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In Brown v. MRS BPO, LLC, the Northern District of Illinois, acting on its own motion, granted summary judgment in favor of the defense on claims asserting violations of the Fair Debt Collections Practices Act (FDCPA)....more

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Federal Magistrate Recommends Dismissal of FDCPA and FCRA Case on Statute of Limitation and Reasonableness of Reporting Grounds

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On November 9, a magistrate judge in the Northern District of Georgia issued a Report & Recommendation to grant a motion to dismiss because the plaintiff’s Fair Debt Collection Practices Act (FDCPA) claims were time-barred...more

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Second Circuit Affirms Dismissal of FDCPA Case Holding Plaintiff Prompted Communication at Issue

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The U.S. Court of Appeals for the Second Circuit issued a summary order affirming a district court’s holding that an emailed response to the plaintiff’s email did not constitute an “initial communication” under the Fair Debt...more

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Undated Model Debt Violation Notice Does Not Violate the FDCPA

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Last week, a district court in Nevada held that an undated, model form debt validation notice does not violate the Fair Debt Collection Practices Act (FDCPA). In Bergida v. PlusFour, Inc., the defendant sent a debt validation...more

Ballard Spahr LLP

NY federal court denies motion to dismiss CFPB lawsuit against debt buyer companies and their owners/officers for unlawful debt...

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A New York federal district court has denied a motion to dismiss the lawsuit filed in January 2022 by the CFPB against three companies that purchase portfolios of defaulted debts (Corporate Defendants) and three individuals...more

Orrick, Herrington & Sutcliffe LLP

District Court denied motion to dismiss CFPA and FDCPA claims against debt buyers

On August 22, the U.S. District Court for the Western District of New York refused to dismiss CFPA and FDCPA claims brought by the CFPB that alleged violations related to misrepresentations made to debtors by debt collectors....more

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Tenth Circuit Affirms Summary Judgment in Favor of Defendant in FDCPA Case on the Basis of Claim Preclusion

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On August 1, the U.S. Court of Appeals for the Tenth Circuit upheld a trial court’s order granting summary judgment in favor of a debt buyer holding that claim preclusion barred the plaintiff’s claims brought under the Fair...more

Ballard Spahr LLP

Seventh Circuit rules $3.95 in postage spent by plaintiff to respond to second validation notice sufficient to establish FDCPA...

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The U.S. Court of Appeals for the Seventh Circuit has ruled that a plaintiff in a putative class action had standing to assert FDCPA claims against the purchaser of her debt and the purchaser’s servicer based on the $3.95 she...more

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CFPB Issues Advisory Opinion on “Zombie Debt”

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On April 26, the Consumer Financial Protection Bureau (CFPB or Bureau) issued an advisory opinion reminding the industry that a debt collector who brings or threatens to bring a foreclosure action to collect a time-barred...more

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Court Finds Entity Partnering With Medical Provider Does Not Qualify as a Debt Collector Under the FDCPA

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In Palacio v. Med. Fin. Sols., No. 21 CV 1288 (N.D. Ill. June 14, 2022), the court granted summary judgment in favor of the defendant, finding that it did not qualify as a “debt collector” under the Fair Debt Collections...more

Venable LLP

Debt Buyer Sued for Deceptive Practices of Downstream Third-Party Collectors; CFPB Uses Its Substantial Assistance Authority

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On January 10, 2022, the Consumer Financial Protection Bureau (CFPB) filed a complaint in federal district court against three affiliated debt-buying businesses and the individuals who founded and operated them for "knowingly...more

Ballard Spahr LLP

CFPB sues debt buyer companies and their owners/officers for unlawful debt collection practices based on third-party conduct

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The CFPB filed a complaint earlier this week in a New York federal district court against three companies that purchase defaulted debts (Corporate Defendants) and three individuals who are owners and/or officers of the...more

Sheppard Mullin Richter & Hampton LLP

Eleventh Circuit orders en banc rehearing in Hunstein

On November 17, a majority of the active judges of the U.S. Court of Appeals for the Eleventh Circuit issued an order sua sponte to rehear Hunstein v. Preferred Collection and Management Services, Inc., en banc. The order...more

Ballard Spahr LLP

CA DFPI brings first enforcement action against a debt collector and debt buyer for violating the state’s Consumer Financial...

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Last week, the California Department of Financial Protection and Innovation (DFPI) brought its first enforcement action against a debt collector and debt buyer for violating the state’s Consumer Financial Protection Law...more

Brownstein Hyatt Farber Schreck

Debt Collection Companies Beware: A Slew of Lawsuits Are Coming

Yesterday, the 11th Circuit Court of Appeals issued an opinion in Hunstein v. Preferred Collection and Management Services, Inc., -- F.3d --, 2021 WL 1556069 (Apr. 21, 2021), which almost immediately set off alarms in the...more

Ballard Spahr LLP

CFPB settles with New Jersey debt buyer for alleged FDCPA and CFPA violations based on unlicensed collection activity

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Earlier this month, the Consumer Financial Protection Bureau issued a consent order against a New Jersey debt buyer accused of threatening and suing consumers to collect debts in states where it did not have a legally...more

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8th Circuit Determines That Evidence Is Required To Prove Vicarious Liability For FDCPA Claims

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The Eighth Circuit Court of Appeals held that the actions of a debt collector are not necessarily imputed to a debt buyer. This holding reversed the Western District of Arkansas District Court, which held that the actions of...more

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District Court Holds Letter Notifying Debtor of Change in Debt Ownership Can Fall Under FDCPA

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On October 5, 2020, the U.S. District Court for the Middle District of Florida denied a debt collector’s motion for summary judgment, holding that a letter which provides notice of a change in debt ownership and requests...more

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

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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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Ninth Circuit rules passive debt buyers qualify as “debt collectors” under FDCPA

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The U.S. Court of Appeals for the Ninth Circuit ruled in McAdory v M.N.S. Associates, LLC and DNF Associates, LLC, in a 2-1 decision, that companies that engage third parties to collect consumer debts they acquired when the...more

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Seventh Circuit holds identification of original and current creditor in debt collection letter did not violate FDCPA

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The U.S. Court of Appeals for the Seventh Circuit affirmed the district court’s judgment on the pleadings in favor of the defendants (a debt buyer and a collection agency) in a putative class action that alleged the...more

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Debt Collector Enters into Consent Order with CFPB to Settle Alleged FDCPA and UDAAP Violations

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Last week, the CFPB announced that that it had entered into a consent order with an Illinois-based debt collection company. According to the settlement, the company’s business consists primarily of purchasing and then...more

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