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Facing CFPB Criticism, Credit Bureaus Dramatically Reduce Medical Debt Credit Reporting

On March 18, the three nationwide consumer reporting agencies — Equifax, Experian, and TransUnion (NCRAs) — announced plans to change how medical debt will be reported on credit reports. The joint measures will result in the...more

Nevada Transiting Collection Agency Related Licenses to NMLS

On February 3, the Nevada Financial Institutions Division (NFID) issued a bulletin, stating that any licensed collection agency or manager must transition their license to the Nationwide Multistate Licensing System (NMLS) by...more

FCRA Litigation: A Look Ahead for 2022 - FCRA Focus Podcast [Audio]

Join Troutman Pepper Consumer Financial Services Partner Dave Gettings for a special podcast series dedicated to exploring the Fair Credit Reporting Act (FCRA). In this inaugural episode, Dave talks with fellow Troutman...more

Court Finds Text Messages Do Not Qualify As Artificial or Prerecorded Voice Messages Under the TCPA

In Eggleston v. Reward Zone USA LLC, No. 2:20-cv-01027-SVW-KS (C.D. Cal. Jan. 28, 2022), the U.S. District Court for the Central District of California rejected the argument that text messages are “artificial or prerecorded...more

3/4/2022  /  ATDS , TCPA , Text Messages , Voicemail

Federal Court Grants Summary Judgment Holding Reporting of Loan During COVID-19 Forbearance as Accurate

In December 2021, a federal judge granted a motion for summary judgment in Mitchell v. Specialized Loan Servicing LLC, holding that defendant Specialized Loan Servicing LLC (Specialized Loan) properly reported plaintiff Eric...more

Federal Court Remands Case Holding That ICRAA Statutory Damages Limited to One Penalty Per Background Report

On January 26, a federal judge granted plaintiff Maria Garcia’s (Garcia) motion to remand on the basis that the amount in controversy was below the required threshold. The order was based on the court’s interpretation of the...more

Third Circuit Hears Oral Argument on FCRA “Pay Status” Cases

On January 20, the Third Circuit Court of Appeals held oral argument in Bibbs v. Trans Union, LLC. This case is a consolidated appeal of multiple decisions from the Eastern District of Pennsylvania, granting dispositive...more

Navient Settles with State AG Coalition Over Alleged Unfair, Deceptive, and Abusive Student Loan Origination and Servicing...

On January 13, a coalition of 39 state attorneys general — led by AGs from Pennsylvania, Washington, Illinois, Massachusetts, and California — reached a settlement with student loan servicer Navient over allegedly unfair,...more

Plaintiff’s Confusion Over Debt Collection Letter Is Not Enough to Create Standing to Assert an FDCPA Claim

In Whitfield v. Contract Callers, Inc., Civil Action No. RDB-21-1540 (D. Md. Dec. 20, 2021), the District of Maryland dismissed claims asserted under the Fair Debt Collection Practices Act (FDCPA), holding that confusion...more

The Sixth Circuit Confirms Plaintiff’s Standing Based on an Alleged Denial of a Loan in Violation of the FCRA and ECOA

In Fillinger v. Third Fed. Sav. & Loan Ass’n, No. 21-3088 (6th Cir. 2021), the Sixth Circuit held that an alleged denial of a loan is a sufficient injury to confer standing under Article III of the Constitution....more

Multiple Interpretations and Credit Reporting: Third Circuit District Court Dismisses Plaintiff’s First Amended Complaint in FDCPA...

In Knight v. AR Res., Inc., a Third Circuit district court granted a defendant’s motion to dismiss a plaintiff’s first amended complaint in a Fair Debt Collection Practices Act (FDCPA) case. In its holding, the court...more

CFPB Publishes Compliance Aids in Anticipation of New Debt Collection Final Rules Becoming Effective

Last month, industry saw the Consumer Financial Protection Bureau (CFPB) issue a number of compliance aids in anticipation of two CFPB Debt Collection Final Rules becoming effective on November 30. On October 1, the CFPB...more

CFPB Issues Advisory Opinion on Name-Only Matching

On November 4, the Consumer Financial Protection Bureau (CFPB) issued an advisory opinion, stating that a consumer reporting agency (CRA) that engages in name-only matching violates the Fair Credit Reporting Act’s (FCRA)...more

CFPB Highlights Extension of Period to Request Initial COVID-19 Hardship Forbearance for Certain Government Backed Loans

On October 4, the Consumer Financial Protection Bureau (CFPB) announced on its website that the deadline to request initial forbearance for a COVID-19 hardship for loans backed by the Federal Housing Administration (HUD/FHA),...more

First Circuit Affirms Final Approval of FCRA Class Action Settlement

In Robinson v. Nat’l Student Clearinghouse, — F.4th — (1st Cir. 2021), a First Circuit panel unanimously affirmed the district court’s Final Approval Order, approving the class settlement in an action brought under the Fair...more

1099C Language in Collection Letters: Third Circuit District Court Grants Defendants’ Motion for Summary Judgment in FDCPA Case

In Bordeaux v. LTD Fin. Servs., L.P., a Third Circuit district court granted summary judgment to the defendants in a Fair Debt Collection Practices Act (FDCPA) case. In its holding, the court emphasized Third Circuit...more

10/7/2021  /  Article III , Debt Collection , FDCPA , IRS , Standing

Court Finds Plaintiff Lacks Standing to Assert FDCPA Claim Based on Disputed Credit Information

In Tolliver v. Nat’l Credit Sys., Inc., No. 20-cv-728-jdp (W.D. Wis. Sep. 22, 2021), the Western District of Wisconsin found that the plaintiff lacked standing to assert his claims for violation of the Fair Debt Collections...more

Seventh Circuit District Court Dismisses FDCPA Case for Lack of Article III Standing

In Friend v. CACH LLC, a district court in the Seventh Circuit dismissed a Fair Debt Collection Practices Act (FDCPA) case for lack of Article III standing. In its holding, the court emphasized that to establish Article III...more

Minnesota Establishes Licensing Requirement for Debt Buyers

Earlier this summer, Minnesota extended many of its collection agency requirements to debt buyers through the enactment of H. F. No. 6. As of January 1, 2022, debt buyers will need to hold a collection agency license or have...more

Signing Bonuses and Article III Standing: Seventh Circuit Reverses and Remands District Court Entry of Summary Judgment for...

In Wadsworth v. Kross, Liberman & Stone, Inc., the Seventh Circuit Court of Appeals reversed a district court’s entry of summary judgment for the plaintiff in a Fair Debt Collection Practices Act (FDCPA) case and remanded the...more

Tenth Circuit Affirms Rejection of Bona Fide Error Defense in FDCPA Claim Alleging a Single Collection Call After Receipt of a...

In Lupia v. Medicredit, Inc., No. 20-1294 (10th Cir. Aug. 17, 2021), the Tenth Circuit affirmed summary judgement in favor of the plaintiff in a claim under the Fair Debt Collections Practices Act (FDCPA), finding that the...more

CFPB Issues Interpretive Rule on Juneteenth and Mortgage Disclosure Requirements

On June 17, the president signed legislation designating “Juneteenth National Independence Day, June 19” as a federal holiday. Because the legislation took effect immediately, it raised compliance questions for residential...more

Court Grants Summary Judgment in Favor of Defendant Debt Collector in a FDCPA Case Concerning a Disputed Debt

In Burns v. Keybridge Med. Revenue Care, No. 2:20-cv-12732 (E.D. Mich. July 22, 2021), the Eastern District of Michigan granted summary judgment in favor of a debt collector, holding that it did not violate the Fair Debt...more

New York District Court Dismisses Six FDCPA Cases Invoking “Mailing Vendor” Theory Emanating from the Eleventh Circuit Hunstein...

In In re FDCPA Mailing Vendor Cases, a New York district court dismissed six FDCPA complaints after plaintiffs in each of the respective cases failed to demonstrate injury-in-fact sufficient for Article III standing in...more

CFPB Issues the 2021 Mortgage Servicing COVID-19 Rule

On June 28, the Consumer Financial Protection Bureau (CFPB) issued a final rule to amend Regulation Z’s mortgage servicing requirements in order to “establish temporary special safeguards to help ensure that borrowers have...more

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