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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

For Your Information: Third Circuit Rejects Article III Standing Based on Informational Injury Doctrine in FDCPA Class Action

On October 12, the U.S. Court of Appeals for the Third Circuit issued a decision rejecting a district court’s finding that the so-called informational injury doctrine established Article III standing for the named plaintiff...more

New Jersey Federal Court Holds Bank Levy Provides Basis for Standing in FDCPA Case

On September 15, the U.S. District Court for the District of New Jersey denied the defendant’s summary judgment motion holding instead that a bank levy against the plaintiff served as a basis for standing to assert a claim...more

Michigan Federal Court Grants Summary Judgment to Creditor on Standing Grounds in Case Alleging FDCPA Violation for Failure to...

On September 7, the U.S. District Court for the Eastern District of Michigan granted summary judgment in the defendant’s favor finding that the plaintiff had not suffered a concrete injury and therefore lacked standing to...more

Seventh Circuit Affirms Dismissal of FDCPA Claim for Lack of Standing, Holding Hiring a Lawyer and Confusion is Not Enough

The Seventh Circuit Court of Appeals recently affirmed a district court’s dismissal of a suit holding that the plaintiff had not suffered a concrete injury, and therefore, lacked standing to assert a claim under the Fair Debt...more

New York Federal Court Sides with CFPB, Denies Debt Holders’ Motions to Dismiss Case Alleging Violations of the FDCPA and CFPA

On August 22, a district court judge in the Western District of New York denied the defendants’ motions to dismiss a case brought by the Consumer Financial Protection Bureau (CFPB) alleging violations of the Fair Debt...more

New York District Court Approves Class Action in FDCPA Case Alleging Improper Debt Assignment Notification

On August 18, a judge in the U.S. District Court for the Western District of New York granted the plaintiff’s motion for class certification for alleged violations of the Fair Debt Collections Practices Act (FDCPA) relating...more

Troutman Pepper Weekly Consumer Financial Services Newsletter - August 2023 #2

To help you keep abreast of relevant activities, below find a breakdown of some of the biggest events at the federal and state levels to impact the Consumer Finance Services industry this past week...more

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

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

FTC Fines Bankrupt Crypto Services Provider Celsius $4.7B for Misrepresentations; Regulatory Agency Remains in Search for Civil...

Deceptive advertisements, market manipulation, misappropriation of customer funds, and “Ask Me Anything (AMA)” sessions served as the catalysts of a civil enforcement action the Federal Trade Commission (FTC) recently filed...more

Ninth Circuit Rejects Constitutional Challenge to Nevada Medical Debt Legislation; Also Finds Legislation Not Preempted by FDCPA...

Last week, the Ninth Circuit Court of Appeals affirmed a lower court’s denial of preliminary injunctive relief to plaintiffs challenging Nevada Senate Bill 248 (S.B. 248), which places new restrictions on the collection of...more

CFPB Enters Consent Order Against Medical Debt Collector for Alleged FCRA and FDCPA Violations

On June 8, the Consumer Financial Protection Bureau (CFPB) announced that it had entered a consent order against medical debt collector Phoenix Financial Services for alleged violations of the Fair Credit Reporting Act (FCRA)...more

Ohio Federal Court Holds Mortgage Lender’s Assessment of Post-Acceleration Late Fees Was Authorized by Loan Documents

In Schmitt v. Security National Servicing Corporation, the plaintiff filed a class action complaint alleging violations of the Fair Debt Collection Practices Act (FDCPA) and Ohio Residential Mortgage Lending Act (RMLA)...more

Troutman Pepper Weekly Consumer Financial Services Newsletter - May 2023

To help you keep abreast of relevant activities, below find a breakdown of some of the biggest events at the federal and state levels to impact the Consumer Finance Services industry this past week...more

Illinois State Court Finds Debt Collector’s Communication to Letter Vendor Was Not Made in Connection With the Collection of a...

On March 15, Judge Eve M. Reilly of the Circuit Court of Cook County, Illinois, dismissed a class action complaint based solely on the allegation that a collection letter was sent by a third-party letter vendor....more

Sixth Circuit Affirms Summary Judgment Finding Defendant Not a “Debt Collector” Under the FDCPA Where Account Was Not in Default...

As discussed here, in August 2020, a district court for the Middle District of Tennessee held that a medical provider’s third-party billing servicer did not qualify as a debt collector under the Fair Debt Collections...more

Hunstein Dismissed

As discussed here, on September 8, 2022, an en banc panel of the Eleventh Circuit Court of Appeals reversed the district court’s decision that a debt collector’s outsourcing of its letter process to a third-party mail vendor...more

CFPB Settles Pending “Meaningful Attorney Involvement” Lawsuit

On January 11, the Consumer Financial Protection Bureau (CFPB) announced it reached a settlement with law firm Forster & Garbus, LLP in its lawsuit over alleged illegal debt collection practices. Specifically, the CFPB...more

Eleventh Circuit: Mini-Miranda Warning on Periodic Statements Can Be Considered Debt Collection Under FDCPA

Earlier this year, the Eleventh Circuit reversed the dismissal of a lawsuit when it held that monthly mortgage statements required by the Truth in Lending Act (TILA) and Regulation Z can constitute communications in...more

Tenth Circuit Adopts “Reasonable Consumer” Standard to Determine Materiality Under FDCPA

The standard courts should use to determine whether an alleged Fair Debt Collection Practices Act (FDCPA) violation is material remains unsettled. According to a recent Tenth Circuit decision, however, the standard should be...more

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