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California Federal Court Halts Allegedly Deceptive Debt Collection Practices by Blackrock Services, Inc. and Affiliates

On February 27, the Federal Trade Commission (FTC) successfully obtained a temporary restraining order against Blackrock Services, Inc. and its associated entities and individuals. The court order aims to halt the defendants’...more

Seventh Circuit Reverses Summary Judgment in FDCPA Debt Dispute Case

This week, the U.S. Court of Appeals for the Seventh Circuit issued a decision reversing a summary judgment order in a Fair Debt Collection Practices Act (FDCPA) case. The court found that there were genuine issues of...more

CFPB Voluntarily Extends Effective Date of Advisory Opinion on Medical Debt

Earlier this month, we discussed the lawsuit filed by ACA International, LLC and Collection Bureau Services, Inc. in the U.S. District Court for the District of Columbia against the Consumer Financial Protection Bureau (CFPB...more

House Resolution Introduced to Disapprove the CFPB Advisory Opinion on Medical Debt Collection Practices

On November 13, Representative Gary J. Palmer (R-AL) introduced House Joint Resolution 220, which seeks congressional disapproval of an advisory opinion published by the Consumer Financial Protection Bureau (CFPB or Bureau)...more

NYC DCWP Clarifies Amended Definition of “Debt Collector” Still Includes Creditors

In our previous post, we discussed the New York City Department of Consumer and Worker Protection’s (NYC DCWP) decision to delay the enforcement of the amended debt collection rules from December 1, 2024, to April 1, 2025....more

FTC Halts Debt Collector Over Alleged $7.6 Million Scheme

Late last month, the Federal Trade Commission (FTC) filed suit against Global Circulation, Inc. (GCI) and its owner for engaging in deceptive and abusive debt collection practices. According to the FTC, the Georgia-based debt...more

NYC DCWP Announces New Effective Date for Amended Debt Collection Rules

On November 1, the New York City Department of Consumer and Worker Protection (NYC DCWP) announced that the effective date for the amended debt collection rules has been officially moved to April 1, 2025....more

NYC DCWP Delays Enforcement of Amended Debt Collection Rules

This week, we discussed the constitutional legal challenge against New York City’s recently amended debt collection rules, which were scheduled to go into effect on December 1, 2024. These rules would stringently regulate...more

New York City’s Amended Debt Collection Rules Draw Legal Challenge

New York City’s recently amended debt collection rules — scheduled to go into effect on December 1, 2024 and which would stringently regulate various debt collection activities by debt collectors operating in the city — have...more

Troutman Pepper Weekly Consumer Financial Services Newsletter- October 2024 # 2

To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week...more

CFPB Intensifies Scrutiny on Medical Debt Collection Practices

On October 1, the Consumer Financial Protection Bureau (CFPB or Bureau) issued an advisory opinion aimed at debt collectors and emphasizing their obligations under the Fair Debt Collection Practices Act (FDCPA) and Regulation...more

California Enacts New Debt Collection Legislation

On September 24, California Governor Gavin Newsom signed into law a package of consumer protection laws, with three bills aimed directly at collection practices. These new laws introduce significant changes in the areas of...more

Nevada Federal Court Grants Summary Judgment in Debt Collector’s Favor in FDCPA and TCPA Case Alleging Attorney Representation and...

On September 9, the U.S. District Court for the District of Nevada granted summary judgment in favor of a debt collector in a case involving alleged violations of the Fair Debt Collection Practices Act (FDCPA) and the...more

Illinois Passes Legislation to Ban Reporting of Medical Debt

On May 16, the Illinois legislature passed Senate Bill (SB) 2933. The bill amends the Illinois Consumer Fraud and Deceptive Business Practices Act making it unlawful for a consumer reporting agency (CRA) to create a consumer...more

California Federal Court Rules Undated Model Debt Violation Notice Does Not Violate the FDCPA

In March, a district court in the Eastern District of California followed other courts holding that an undated, model form debt validation notice does not violate the Fair Debt Collection Practices Act (FDCPA). Specifically,...more

Nevada Federal Court Declines to Decide at Summary Judgment Stage Whether Pre-Dispute Investigation Was Sufficient to Satisfy FCRA

A federal district court judge in Nevada recently denied competing motions for summary judgment in a Fair Credit Reporting Act (FCRA) furnisher investigation case, demonstrating the challenges FCRA litigants often face in...more

CFPB Amicus Brief Supports FDCPA Claim for Unknowing Stay Violation

On January 2, the Consumer Financial Protection Bureau (CFPB) filed an amicus curiae brief urging the U.S. Court of Appeals for the First Circuit to reverse a district court’s decision finding that a debt collector lacked the...more

CFPB Shuts Down Medical Debt Collector for Attempting to Collect Unverified Debt

On December 15, the Consumer Financial Protection Bureau (CFPB) announced it had reached a settlement with medical debt collector Commonwealth Financial Systems, Inc. (Commonwealth) in its lawsuit over alleged illegal debt...more

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

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

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

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

Medical Debt Under the Microscope: Insights from the CFPB’s 2022 FDCPA Report

On November 16, the Consumer Financial Protection Bureau (CFPB or Bureau) released its Fair Debt Collection Practices Act (FDCPA) Annual Report detailing the CFPB’s 2022 activities related to debt collection practices. This...more

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

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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