Who Is the Creditor? Who Is the Debt Collector? Labels vs. Inferences

Maribel Ocampo v. Client Services, Inc. (1:18-cv-04326-BMC,EDNY, 7/3/2019) is a recent case with some interesting perspectives on identifying creditors in FDCPA validation letters and object lessons for debt collectors in writing them. Let’s get right to it by looking at the disputed terms of the letter, reproduced in the debt collector’s filings: RE:                                                 Synchrony Bank … More Who Is the Creditor? Who Is the Debt Collector? Labels vs. Inferences

Review of the Proposed FDCPA Validation Notice Regulations

On May 7, 2019 the Consumer Financial Protection Bureau (CFPB) released its Notice Of Proposed Rulemaking (NPRM) proposing debt collection regulations. I previously blogged about the need for such regulations. Today I want to take a look at the NPRM proposed rules for the validation notice. The Federal Fair Debt Collection Practices Act (FDCPA) 15 … More Review of the Proposed FDCPA Validation Notice Regulations