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Avila Safe Harbor Language: New York District Court Grants Motion for Judgment on the Pleadings for Defendant in FDCPA Case

In Klein v. Forster & Garbus LLP, a New York district court granted the defendant debt collector’s motion for judgment on the pleadings and denied the plaintiff’s request to amend his complaint in a Fair Debt Collection...more

CFPB Issues Interpretive Rule Outlining Authority to Conduct MLA Examinations

On June 16, the Consumer Financial Protection Bureau (CFPB) issued an interpretive rule to explain the basis for its position that the CFPB possesses the authority to “examine supervised financial institutions for risks to...more

Florida Supreme Court Quashes Third District Holding: Note Supersedes Mortgage if Conflict Arises

In WVMF Funding v. Palmero, the Supreme Court of Florida quashed the Third District Court of Appeals’ holding in OneWest Bank, FSB v. Palmero, 283 So. 3d 346 (Fla. 3d DCA 2019) that Mrs. Palmero was a “borrower” under a...more

Second Circuit Rules Private Student Loans May Be Discharged in Bankruptcy

On July 15, the U.S. Court of Appeals for the Second Circuit ruled that private student loans are not explicitly exempt from a debtor’s Chapter 7 bankruptcy discharge....more

Court Finds Calls Triggered by Alarm System Do Not Violate the TCPA

In Watts v. Emergency Twenty Four, Inc. (No. 20-cv-1820 (N.D. Ill. June 21, 2021), the Northern District of Illinois granted a motion to dismiss claims asserted against a security company under the Telephone Consumer...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

Rental Property and the FDCPA: Ninth Circuit Reverses and Remands Entry of Summary Judgment for Defendants-Appellees in FDCPA Case

In Glawe v. Carpenter, Hazelwood, Delgado & Boren PLC, the Ninth Circuit Court of Appeals reversed and remanded the district court’s entry of summary judgment for the appellees-defendants in a Fair Debt Collection Practices...more

Supreme Court Decision: TransUnion v. Ramirez

Today, the Supreme Court issued its opinion in TransUnion LLC v. Ramirez, holding that a concrete injury requires more than the existence of a risk of harm that never materializes. Accordingly, the vast majority of the absent...more

Indiana District Court Grants Partial Summary Judgment for Defendant in FDCPA Case

In Kinnick v. Med-1 Solutions LLC, an Indiana district court granted partial summary judgment for the defendant in a Fair Debt Collection Practices Act (FDCPA) case. In its holding, the court emphasized that requesting that...more

Circuit Split on Class Feasibility Offers Defense Opportunities

Defense counsel tend to see individualized issues of fact and law when litigating a class action. Plaintiffs counsel, on the other hand, will often look at those same issues and suggest that they apply uniformly across the...more

The Scope of the Least Sophisticated Consumer Standard: New York District Court Grants Defendant’s Motion to Dismiss in FDCPA Case

In Teitelbaum v. I.C. Sys., a New York district court granted a defendant’s motion to dismiss in a Fair Debt Collection Practices Act (FDCPA) case. In its holding, the court emphasized that the least sophisticated consumer...more

Court Finds Plaintiff’s Subjective Interpretation of a Debt Collection Letter Insufficient to Confer Standing Under the FDCPA

The Southern District of Florida has added to the growing collection of cases under the Fair Debt Collections Practices Act (FDCPA) based on a lack of standing....more

CFPB Issues Rule Delaying the Mandatory Compliance Date of the New General Qualified Mortgage Final Rule

On April 27, the Bureau of Consumer Financial Protection (CFPB) issued a final rule to delay the mandatory compliance date for the General QM Final Rule until October 1, 2022. The CFPB stated that it issued the rule “to help...more

“Consumer Debt” and Collection Letters: Arizona District Court Denies Plaintiff’s Motion for Partial Judgment on the Pleadings

In Uvaldo v. Germain Law Office PLC, an Arizona District Court denied a plaintiff’s motion for partial judgment on the pleadings in a Fair Debt Collection Practices Act case. In its holding, the court emphasized that the...more

CFPB Takes Actions to Limit COVID-19-Related Mortgage Foreclosures

On April 5, the Consumer Financial Protection Bureau (CFPB) issued a notice of proposed rulemaking (NPR) to amend Regulation Z, specifically to “prevent avoidable foreclosures” due to the COVID-19 pandemic “as the emergency...more

District Court Denies CFPB’s Untimely Attempt to Ratify — Punts on “Covered Persons”

In Consumer Fin. Prot. Bureau v. Nat’l Collegiate Master Student Loan Trust, the District of Delaware dismissed a lawsuit brought by the Consumer Financial Protection Bureau (CFPB), alleging that a group of trusts that hold...more

Compelling Arbitration: The Eleventh Circuit Court of Appeals Reverses and Remands a District Court Holding Denying Defendant’s...

In Hearn v. Comcast Cable Communications, LLC, the Eleventh Circuit Court of Appeals reversed a district court holding denying the defendant’s motion to compel arbitration regarding the plaintiff’s Fair Credit Reporting Act...more

A Chainsaw, Rather than a Scalpel: Supreme Court Holds Telephony Must Include Random or Sequential Number Generator to Qualify as...

In a unanimous decision, the U.S. Supreme Court decided Duguid v. Facebook, finding once and for all that an automatic telephone dialing system (ATDS) as defined by the Telephone Consumer Protection Act (TCPA) requires a...more

Supreme Court Considers Standing and Typicality for No-Injury Class Actions in TransUnion v. Ramirez Oral Argument

The U.S. Supreme Court heard oral argument yesterday in TransUnion LLC v. Ramirez, a case in which the Supreme Court is once again grappling with the requirements of Article III standing — this time in the context of class...more

District of Nevada Grants Motion to Dismiss Claim Alleging Attempts to Recover Collection Fees Violated the FDCPA

In Ahmed v. Richland Holdings, No. 2:19-CV-1925 JCM (DJA) (D. Nev. Feb. 26, 2021), the District of Nevada dismissed a pair for claims under the Fair Debt Collections Practices Act (FDCPA), alleging that a debt collector had...more

CFPB Proposes to Delay the Mandatory Compliance Date of the New General Qualified Mortgage Final Rule

On February 23, the Consumer Financial Protection Bureau (CFPB) issued a statement that it planned to propose a rule to “delay the July 1, 2021 mandatory compliance date of the General QM Final Rule.” Consistent with that,...more

2020 Consumer Financial Services Year in Review & A Look Ahead

2020 was a transformative year for the consumer financial services world. As we navigate an unprecedented volume of industry regulation, Troutman Pepper is uniquely positioned to help its clients find successful resolutions...more

The FDCPA and Foreclosures: Ninth Circuit District Court Denies Defendant’s Motion for Summary Judgment on All Counts

In Milburn v. SN Servicing, LLC, a district court in the Ninth Circuit denied a defendant’s motion for summary judgment regarding the plaintiffs’ allegations that the defendant violated the Fair Debt Collection Practices Act...more

FDCPA Standing: Seventh Circuit District Court Affirms That “Annoyance and Confusion” Without Detrimental Action is Insufficient...

In O’Toole v. Bob Roache Law, a Seventh Circuit District Court in Indiana granted a defendant’s motion to dismiss a Fair Debt Collection Practices Act (FDCPA) case for lack of standing. In its holding, the court emphasized...more

Debt Collector’s Validation of Debt Did Not Violate the FDCPA as a Matter of Law

On February 2, Judge Robert T. Dawson, in the Western District of Arkansas, granted a defendant debt collector’s motion for summary judgment. The court determined Monterey Financial Service LLC’s responses to plaintiff Kyle...more

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