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Third Circuit holds creditors should investigate all indirect disputes of accounts on a credit report [Video]

In this episode of Consumer Finance Compass, Balch’s Jason Tompkins, partner in Balch & Bingham’s Consumer Finance Compliance & Defense Practice, explores the Third Circuit’s new decision holding that furnishers have no...more

Eleventh Circuit’s “Narrow” Holding May Open Wide Disputes About Duties Under The FCRA

The Eleventh Circuit recently weighed in on a common practice—reporting debts subject to bankruptcy. In the process of so doing, the opinion in Losch v. Nationtar Mortgage LLC provided litigants some key insights in Fair...more

Eleventh Circuit Holds Commonplace Use of Letter Vendors May Violate FDCPA and Further Expands Consumer Standing in Huntstein v....

To start with the headline, on April 21, 2021, the Eleventh Circuit Court of Appeals held that a debt collector sending personal identifying information to dunning letter vendors states a claim under the Fair Debt Collection...more

Plain-text reading of TCPA prevails in Facebook, SCOTUS says autodialers must store or produce numbers using a random or...

Few decisions in the world of the Telephone Consumer Protection Act (“TCPA”) have been more awaited than Facebook, Inc. v. Duguid, 592 U.S. — (2021). There, the Supreme Court of the United States (“SCOTUS”) wrestled with the...more

Compelling Arbitration of TCPA Claims Alive and Well

Two recent opinions show that litigants should always determine whether compelling arbitration is viable tactic in fighting claims under the Telephone Consumer Protection Act (TCPA). ...more

TCPA Vicarious Liability Passes from Collector Through Servicer to Original Creditor

The Ninth Circuit Court of Appeals recently held that an original creditor was liable under the Telephone Consumer Protection Act (TCPA) for calls made by a debt collector with which the creditor had no contractual...more

5/13/2019  /  Debt Collection , Debt Collectors , FCC , TCPA

CFPB Issues FDCPA Proposed Rule: A Detailed Overview

On May 7, 2019, the Consumer Financial Protection Bureau (CFPB) released a much anticipated proposed rule regarding the Fair Debt Collection Practices Act (FDCPA). ...more

FDCPA Plaintiff Lacks Standing to Bring Class Action for Validation Letter

In Pozzuolo v. Portfolio Recovery Associates, LLC, the Eastern District of Pennsylvania recently dismissed the named plaintiff of a putative class action for lack of standing to bring suit. ...more

TCPA Insurance Coverage: A Glimmer of Hope?

In 2017, National Union Fire Insurance Co. of Pittsburg, Pa. successfully obtained dismissal of an insurance denial suit by Yahoo! brought in the U.S. District Court for the Northern District of California....more

5/2/2019  /  Appeals , CA Supreme Court , TCPA , Yahoo!

Doesn’t Matter if You Didn’t Put a Ring On It: Ringless Voicemails Are “Calls” Under the TCPA

The Southern District of Florida recently ruled that ringless voicemails (RVM) are “calls” under the Telephone Consumer Protection Act (TCPA). In Schaevitz v. Braman Hyundai, No. 1:17-cv-23890 (S.D. Fla. Mar. 25, 2019) the...more

Applying Reyes: Contractually Controlling Revocation of Consent Under the TCPA

Last week the District of Ohio, in Barton v. Credit One Financial, held that a consumer could not orally and unilaterally revoke consent under the Telephone Consumer Protection Act (TCPA) to be called once given...more

5/8/2018  /  Consent , Credit Cards , Revocation , TCPA

States’ Copycat TCPA Statutes: Double Dipped Damages and Attorneys’ Fees

In Boger v. Trinity Heating & Air, Inc., a court in the District of Maryland permitted Boger to bring simultaneous claims under the Maryland Telephone Consumer Protection Act (MTCPA) and the federal Telephone Consumer...more

4/26/2018  /  Attorney's Fees , Damages , TCPA

No Bill of Sale, No Problem: Compelling Arbitration of FDCPA Claims

Last week, in Fuller v. Frontline Asset Strategies, Inc., the Northern District of Illinois compelled arbitration of Fair Debt Collection Practices Act (FDCPA) claims against LVNV Funding, LLC (LVNV), Resurgent Capital...more

FCRA Climbing the Ladder for Top Consumer Litigation Statute

According to a report from leading litigation-monitoring service WebRecon, Fair Credit Reporting Act (FCRA) filings have begun to outnumber Telephone Consumer Protection Act (TCPA) filings across the country in recent months....more

The Truth Brings Relief Under FCRA

In Ratliff v. A&R Logistics, Inc., the plaintiff claimed A&R denied him a job based on a background check without the appropriate adverse action process. Under the Fair Credit Reporting Act (FCRA), notice pre- and...more

That’s No Autodialer: D.C. Circuit Unwinds 2015 FCC TCPA Ruling

This article addresses the Court’s reversal of over a decade of confusion regarding autodialers. The TCPA defines an autodialer (automatic telephone dialing system, or ATDS) as “equipment which has the capacity (a) to store...more

Revoking Contractual Consent is Different: D.C. Circuit Unwinds 2015 FCC TCPA Ruling

Here, we address one significant component of the decision: the D.C. Circuit’s confirmation that consumers may revoke consent to call by any reasonable means but with the qualification that parties may be able to contract...more

No Safe Harbor for Reassigned Numbers: D.C. Circuit Unwinds 2015 FCC TCPA Ruling

Here, we examine the D.C. Circuit’s reversal of not simply the one-call safe harbor for reassigned numbers imposed by the FCC’s 2015 TCPA ruling but also the Commission’s treatment of reassigned numbers as a whole. ...more

D.C. Circuit Unwinds 2015 FCC TCPA Ruling: An Overview

In a watershed case, the United States Court of Appeals for the District of Columbia Circuit (D.C. Circuit) unwound key components of the controversial 2015 ruling by the Federal Communications Commission (FCC or Commission)...more

Eleventh Circuit Allows Partial Revocation of Consent under TCPA with Class and Contractual Consent Implications

Last week, in Schweitzer v. Comenity Bank, the Eleventh Circuit held that a consumer can partially revoke consent to be called under the Telephone Consumer Protection Act (TCPA). Schweitzer gave her cell phone number when...more

What to Do Now About the New CFPB Rule on Arbitration?

What to do now about the new CFPB rule on arbitration? (1) begin planning now and (2) begin actual preparation after the 60 days runs. Congress has 60 days after publication of the new CFPB rule to take action to stop the...more

Are Existing Agreements Governed by the New CFPB Arbitration Rule?

The Dodd Frank Act expressly provided that any CFPB rule on arbitration would not apply to existing contracts. 12 U.S.C. § 5518(d). Therefore, the CFPB rule released last week will only bar class action waivers for...more

CFPB Kills Class Action Waivers in Consumer Contracts and Makes Arbitration Public

The Consumer Financial Protection Bureau (CFPB) issued a rule yesterday prohibiting class action waivers in arbitration provisions of certain consumer contracts. The rule—to be codified at 12 C.F.R. § 1040—does far more than...more

Second Circuit Says Contractual TCPA Consent Not Revocable

Last week, the Second Circuit Court of Appeals, in Reyes v. Lincoln Automotive Financial Services, held that contractual consent—once given—cannot be unilaterally revoked. The landmark Telephone Consumer Protection Act (TCPA)...more

SCOTUS’s FDCPA Opinion in Henson v. Santander: It’s Not Debt Collection When You Own It

Yesterday, the Supreme Court of the United States issued its opinion in Henson v. Santander Consumer USA, Inc.—Justice Gorsuch’s first as a Supreme Court Justice. The question presented was whether “individuals and entities...more

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