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Minnesota Passes Laws Affecting Debt Buyers

On June 26, Minnesota Governor Tim Walz signed into law a bill that expands the regulation of the accounts receivable management industry to include debt buyers and affiliated companies....more

Washington District Court Awards $60,000 in Emotional Distress Damages to Plaintiffs in FDCPA Case

In Johnson v. Columbia Debt Recovery, a Washington district court awarded each plaintiff $30,000 in emotional distress damages under the Fair Debt Collection Practices Act (FDCPA), $120 in treble actual damages under the...more

Troutman Pepper Weekly Consumer Financial Services COVID-19 Newsletter - Junes 2021 #4

Like most industries today, Consumer Finance Services businesses are being significantly impacted by the novel coronavirus (COVID-19). Troutman Pepper has developed a dedicated COVID-19 Resource Center to guide clients...more

Eastern District of New York Holds that Reference to the Possibility of Reviewing Legal Options Is Not an Empty Threat Under the...

In Mikhael v. Credit Corp Solutions, Inc., the Eastern District of New York held that a letter alluding to the possibility of referring an account to an attorney for review does not constitute a threat to take imminent action...more

Troutman Pepper Weekly Consumer Financial Services COVID-19 Newsletter - June 2021 #2

Like most industries today, Consumer Finance Services businesses are being significantly impacted by the novel coronavirus (COVID-19). Troutman Pepper has developed a dedicated COVID-19 Resource Center to guide clients...more

Troutman Pepper Weekly Consumer Financial Services COVID-19 Newsletter - May 2021 #2

Like most industries today, Consumer Finance Services businesses are being significantly impacted by the novel coronavirus (COVID-19). Troutman Pepper has developed a dedicated COVID-19 Resource Center to guide clients...more

Western District of Washington Denies Defendant’s Motion to Dismiss Based on Plaintiff’s Allegations That She Did Not Owe the Debt

In Tinsley v. Fairway Collections, LLC, the Western District of Washington recently issued an opinion finding that dismissal of a consumer’s FDCPA claim was not warranted because she alleged not owing the underlying debt at...more

Eleventh Circuit Throws Debt Collectors Under the FDCPA Bus for Sharing Account Information with Letter Vendors

In a panel decision on April 21, the Eleventh Circuit held that (1) a consumer had standing to bring a claim under the Fair Debt Collection Practices Act (FDCPA) because he alleged an invasion of privacy based on the spread...more

Display of Data Symbols Similar to QR Code Visible Through Envelope Window Insufficient to Establish Article III Standing

In Nyanhongo v. Credit Collections Servs., the Eastern District of Pennsylvania held that the display of “data symbols similar to a” quick response code (QR Code), without more, was insufficient to establish Article III...more

Third Circuit Affirms Motion to Dismiss FDCPA Claim Over Itemization of “$0.00” in Interest and Collection Charges

In Hopkins v. Collecto, Inc., the Third Circuit Court of Appeals affirmed the dismissal of a putative class-action complaint, alleging that by itemizing interest and collection fees for a “static debt,” the letter violated...more

CFPB Settles with Yorba Capital Over Debt Collection Litigation Notices

On April 6, the Consumer Financial Protection Bureau (CFPB) issued a consent order against California-based debt collector Yorba Capital Management LLC and its sole owner Daniel Portilla, Jr. for violating the Consumer...more

Second Circuit Holds Reporting a Judgment as “Satisfied” was Accurate and Provides Guidance on Defending Claims for Willfully...

The Second Circuit Court of Appeals recently upheld a ruling that reporting a judgment as “satisfied” was accurate under the Fair Credit Reporting Act (FCRA) when the underlying lawsuit was dismissed by stipulation as...more

Troutman Pepper Weekly Consumer Financial Services COVID-19 Newsletter - April 2021 #2

Like most industries today, Consumer Finance Services businesses are being significantly impacted by the novel coronavirus (COVID-19). Troutman Pepper has developed a dedicated COVID-19 Resource Center to guide clients...more

Third Circuit Rejects Debtor’s Claim that Invitation to Call Deceives Debtors of Legally Effective Means of Disputing a Debt

In Moyer v. Patenaude & Felix, A.P.C., the Third Circuit Court of Appeals affirmed the dismissal of a putative class action complaint, alleging that including an invitation to call the debt collector to “eliminate further...more

Bill Limiting a Hospital’s Means of Collecting Past Due Medical Debt Poised to Become Law

Last week, the Maryland Senate and the House of Representatives each voted unanimously to approve bills that would limit a hospital’s means of collecting past due medical debt. Senate Bill 0514 and House Bill 0565 now move...more

2020 Consumer Financial Services Year in Review & A Look Ahead

2020 was a transformative year for the consumer financial services world. As we navigate an unprecedented volume of industry regulation, Troutman Pepper is uniquely positioned to help its clients find successful resolutions...more

CFPB Issues Small Entity Compliance Guide on Debt Collection Rule

On January 21, the CFPB issued a Small Entity Compliance Guide summarizing the October 2020 Debt Collection Rule. The Debt Collection Rule amends Regulation F, 12 CFR Part 1006 and becomes effective on November 30, 2021. The...more

Factually v. Legally Inaccurate Information, The Difference Matters: Court Rejects FCRA Claims Based on Disputed Legal Issue

On January 21, 2021, the United States District Court for the Northern District of Illinois granted TransUnion Data Solutions LLC’s (Trans Union) motion for judgment on the pleadings, denying Blue Sobenes’ (Sobenes) claims...more

Troutman Pepper Weekly Consumer Financial Services COVID-19 Newsletter - January 2021 #3

Like most industries today, Consumer Finance Services businesses are being significantly impacted by the novel coronavirus (COVID-19). Troutman Pepper has developed a dedicated COVID-19 Resource Center to guide clients...more

7th Circuit Challenges Whether Plaintiffs Had Standing in Recent District Court Cases

On December 15, 2020, the Seventh Circuit Court of Appeals decided four cases which all dealt with the issue of standing within the context of the Fair Debt Collection Practices Act (“FDCPA”). With these holdings, the Seventh...more

District Court Dismisses FDCPA Claim Regarding Disputed Debt, Leaves Open FCRA Claim Involving Use of the CFPB Portal to Submit a...

The Eastern District of New York recently decided a motion to dismiss, denying Defendant’s motion as to Plaintiff’s claims under the FCRA and dismissing Plaintiff’s claims under the FDCPA....more

Judge Dismisses FDCPA Class Action Brought Over $0 Balance Line Item

Plaintiffs John Slomanski and Margaret Brusewitz brought an FDCPA class action, Slomanski and Brusewitz v. Alliance Collection Agencies, in the Eastern District of Wisconsin alleging that debt collection letters sent to them...more

Ninth Circuit Holds Reliance on Contract Provision by Debt Collector Not Enough for FDCPA “Bona Fide Error” Defense

The Ninth Circuit Court of Appeals held in Urbina v. National Business Factors Inc. that a debt collector cannot use a “bona fide error” defense to shield itself from liability under the Fair Debt Collection Practices Act...more

Texas Court Denies Defendants’ Motion to Dismiss FDCPA Claim Over Statute of Limitations Defense

The Eastern District of Texas recently denied a motion to dismiss for alleged violations of the Fair Debt Collection Practices Act (“FDCPA”), holding that a garnishment action initiated eight years after the plaintiff had...more

Eleventh Circuit Affirms Dismissal of FDCPA Suit Over SOL

The Court of Appeals for the Eleventh Circuit affirmed the dismissal of a Fair Debt Collection Practices Act (“FDCPA”) lawsuit finding Georgia’s six-month statute of limitations renewal statute did not apply to the FDCPA....more

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