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Eleventh Circuit En Banc Panel Reverses Controversial Hunstein Decision

In a much anticipated decision released September 8, 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...more

CFPB Targets Convenience Fees in Latest Advisory Opinion

On June 29, the Consumer Financial Protection Bureau (CFPB or Bureau) issued an advisory opinion focused on consumer debt collectors and the convenience fees they charge for some payments, such as online or by phone....more

Troutman Pepper Weekly Consumer Financial Services COVID-19 Newsletter -December 2021

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

Georgia Court Dismisses FDCPA Case Over Calls to Consumer’s Mother

A recent decision out of the Northern District of Georgia highlights how statutory language is still important when resolving matters under the FDCPA. In this case of Joe v. Capital Link Management LLC, the court held that...more

Eastern District of New York Dismisses FDCPA Complaint Based on Lack of Standing

The Eastern District of New York recently found that a plaintiff lacked Article III standing to bring her FDCPA suit as she failed to demonstrate a concrete, particularized injury. In the case of Bush v. Optio Solutions LLC,...more

Eighth Circuit Holds Boilerplate Disclosures Alone Insufficient to Implicate FDCPA Protections

In Heinz v. Carrington Mortgage Services LLC, the Eighth Circuit held that the mere inclusion of boilerplate disclosure language does not transform an otherwise benign informational communication into one meant to induce...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

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 - 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

Troutman Pepper Weekly Consumer Financial Services COVID-19 Newsletter #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

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

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

Troutman Pepper Weekly Consumer Financial Services COVID-19 Newsletter - March 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

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

Federal Preemption Does Not Always Constitute Grounds For Removal: Court Rejects Removal Based On FCRA And FDCPA Preemption Claims

On January 20, 2021, the Southern District of New York granted Emmanuel Torres’ (“Torres”) motion to remand to state court, holding that Wakefield & Associates’ (“Wakefield”) and Rural Metro Ambulance Corporation’s (“Rural...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

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