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Fair Debt Collection Practices Act
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{{short description|U.S. consumer protection law}} {{Infobox U.S. legislation | shorttitle = Fair Debt Collection Practices Act | othershorttitles = | longtitle = An act to amend the [[Consumer Credit Protection Act]] to prohibit abusive practices by debt collectors. | colloquialacronym = FDCPA | nickname = | enacted by = 95th | effective date = | public law url = | cite public law = {{uspl|95|109}} | cite statutes at large = {{usstat|91|874}} | acts amended = | acts repealed = | title amended = [[Title 15 of the United States Code|Title 15]] | sections created = {{usc|15|1692|1692p}} | sections amended = | leghisturl = https://www.congress.gov/bill/95th-congress/house-bill/5294/ | introducedin = House | introducedbill = H.R.5294 | introducedby = [[Frank Annunzio]] ([[Democratic Party (United States)|D]]–[[Illinois|IL]]) | introduceddate = March 22, 1977 | committees = | passedbody1 = House | passeddate1 = April 4, 1977 | passedvote1 = | passedbody2 = Senate | passedas2 = <!-- used if the second body changes the name of the legislation --> | passeddate2 = August 5, 1977 | passedvote2 = | conferencedate = | passedbody3 = | passeddate3 = | passedvote3 = | agreedbody3 = House | agreeddate3 = September 8, 1977 | agreedvote3 = | agreedbody4 = <!-- used if agreedbody3 further amends legislation --> | agreeddate4 = <!-- used if agreedbody3 further amends legislation --> | agreedvote4 = <!-- used if agreedbody3 further amends legislation --> | passedbody4 = | passeddate4 = | passedvote4 = | signedpresident = [[Jimmy Carter]] | signeddate = September 20, 1977 | unsignedpresident = <!-- used when passed without presidential signing --> | unsigneddate = <!-- used when passed without presidential signing --> | vetoedpresident = <!-- used when passed by overriding presidential veto --> | vetoeddate = <!-- used when passed by overriding presidential veto --> | overriddenbody1 = <!-- used when passed by overriding presidential veto --> | overriddendate1 = <!-- used when passed by overriding presidential veto --> | overriddenvote1 = <!-- used when passed by overriding presidential veto --> | overriddenbody2 = <!-- used when passed by overriding presidential veto --> | overriddendate2 = <!-- used when passed by overriding presidential veto --> | overriddenvote2 = <!-- used when passed by overriding presidential veto --> | amendments = | SCOTUS cases = {{ubl|''Heintz v. Jenkins'', {{ussc|514|291|1995}}|''Jerman v. Carlisle, McNellie, Rini, Kramer & Ulrich LPA'', {{ussc|559|573|2010}}|''Marx v. General Revenue Corp.'', {{ussc|568|371|2013}}|''[[Sheriff v. Gillie]]'', {{ussc|docket=15-338|volume=578|year=2016}}|''Midland Funding, LLC v. Johnson'', {{ussc|docket=16-348|volume=581|year=2017}}|''[[Henson v. Santander Consumer USA Inc.]]'', {{ussc|docket=16-349|volume=582|year=2017}}|''Obduskey v. McCarthy & Holthus LLP'', {{ussc|docket=17-1307|volume=586|year=2019}}|''[[Rotkiske v. Klemm]]'', {{ussc|docket=18-328|volume=589|year=2019}}}} }} The '''Fair Debt Collection Practices Act''' ('''FDCPA'''), [[List of United States federal legislation#Public laws|Pub. L.]] [[95th United States Congress|95]]-109; 91 [[United States Statutes at Large|Stat.]] 874, codified as {{usc|15|1692}} –1692p, approved on September 20, 1977 (and as subsequently amended), is a [[consumer protection]] amendment, establishing legal protection from abusive [[debt collection]] practices, to the [[Consumer Credit Protection Act]], as Title VIII of that Act. The [[statute|statute's]] stated purposes are: to eliminate abusive practices in the collection of consumer [[debt]]s, to promote [[fair debt collection]], and to provide consumers with an avenue for disputing and obtaining validation of debt information in order to ensure the information's accuracy.<ref>{{cite book |title= Intro to Business|last1= Dlabay|first1= Les R. |last2=Burrow |first2=James L. |last3=Brad |first3= Brad |year= 2009|publisher= South-Western [[Cengage Learning]]|location= [[Mason, Ohio]]|isbn=978-0-538-44561-0 |page=472}}</ref> The Act creates guidelines under which debt collectors may conduct business, defines rights of consumers involved with debt collectors, and prescribes penalties and remedies for violations of the Act. It is sometimes used in conjunction with the [[Fair Credit Reporting Act]].<ref>{{cite web|title=Fair Debt Collection Practices Act|url=https://www.law.cornell.edu/wex/fair_debt_collection_practices_act|website=Wex|publisher=Cornell Law School|access-date=14 June 2017}}</ref><ref>{{cite web|title=Fair Debt Collection Practices Act|url=https://www.ftc.gov/enforcement/rules/rulemaking-regulatory-reform-proceedings/fair-debt-collection-practices-act-text|website=Federal Trade Commission|date=12 August 2013 |access-date=14 June 2017}}</ref> ==People and entities covered by the FDCPA== The FDCPA broadly defines a debt collector as "any person who uses any instrumentality of interstate commerce or the mails in any business the principal purpose of which is the collection of any debts, or who regularly collects or attempts to collect, directly or indirectly, debts owed or due or asserted to be owed or due another."<ref>{{usc|15|1692a}}</ref> While the FDCPA generally applies only to third party debt collectors—not internal collectors for an "original [[creditor]]"—some states, such as [[California]],<ref>{{cite web|title=Your Rights Under California's Fair Debt Collection Practices Act|url=https://oag.ca.gov/consumers/general/collection_agencies10|website=State of California Department of Justice|date=10 February 2012 |access-date=16 June 2017}}</ref> have similar state consumer protection laws which mirror the FDCPA, and regulate original creditors. In addition, some federal courts have ruled that a collector of debt is not a "creditor" but is rather a "debt collector" under the FDCPA where the collector of debt [[debt buyer|buys defaulted debt]] from an original creditor for the purpose of debt collection.<ref>''Holmes v. Telecredit Service Corp.'', 736 F. Supp. 1289, 1293 (D. Del. 1990)</ref><ref>''Kimber v. Federal Financial Corp.'', 668 F. Supp. 1480, 1485 (M.D.Ala. 1987)</ref><ref>{{cite web|title=Federal Trade Commission Staff Opinion Letter Dated Dec. 22, 1993 (|url=http://www.ftc.gov/os/statutes/fdcpa/letters/arbuckle.htm|website=Federal Trade Commission|access-date=16 June 2017|archive-url=https://web.archive.org/web/20070224093350/http://www.ftc.gov/os/statutes/fdcpa/letters/arbuckle.htm|archive-date=24 February 2007|date=22 December 1993}}</ref> The definitions and coverage have changed over time. The FDCPA itself contains numerous exceptions to the definition of a "debt collector", particularly after the October 13, 2006, passage of the Financial Services Regulatory Relief Act of 2006. Attorneys, originally explicitly exempted from the definition of a debt collector, have been included (to the extent that they otherwise meet the definition) since 1986. The FDCPA's definitions of "consumers" and "debt" specifically restricts the coverage of the act to personal, family or household transactions.<ref>{{cite web|title=15 U.S. Code § 1692a - Definitions|url=https://www.law.cornell.edu/uscode/text/15/1692a|website=Legal Information Institute|publisher=Cornell Law School|access-date=16 June 2017}}</ref> Thus, debts owed by businesses (or by individuals for business purposes) are not subject to the FDCPA. In the federal tax case of ''Smith v. United States'', the United States Court of Appeals for the Fifth Circuit stated that the taxpayer's "invocation of the Fair Debt Collection Act is entirely without merit, as the statute expressly excludes 'any officer or employee of the United States ... to the extent that collecting or attempting to collect any debt is in the performance of his official duties' from the definition of 'debt collector'. 15 U.S.C. section 1692a(6)(C)."<ref name="Smith">''Smith v. United States'', United States Court of Appeals for the Fifth Circuit, case no. 08-10288, December 2, 2008 (''per curiam'').</ref> In 1998, however, Congress amended the Internal Revenue Code by adding a new section 6304, "Fair Tax Collection Practices", which refers to and includes certain rules that are similar to some provisions of the Fair Debt Collection Practices Act.<ref>See generally {{usc|26|6304}}, as enacted by section 3466(a) of the Internal Revenue Service Restructuring and Reform of 1998, Pub. L. No. 105-206 (July 22, 1998).</ref> In ''[[Henson v. Santander Consumer USA Inc.]]'', the Supreme Court excluded collection companies that purchase consumer debt from the FDCPA when it unanimously held that a company may collect debts that it purchased for its own account without triggering the statutory definition of a "debt collector" under the Fair Debt Collection Practices Act.<ref>{{cite web|title=''Henson vs. Satander Consumer USA'', 582 U.S. ___ (2017)|url=https://www.supremecourt.gov/opinions/16pdf/16-349_c07d.pdf|website=Supreme Court of the United States|access-date=16 June 2017}}</ref> Nonetheless, at least one subsequent Circuit Court opinion has cabined the impact of ''Henson'' by subsequently finding that companies that purchase consumer debt could still be subject to the FDCPA under the alternative definition of debt collector as a business whose "principal purpose" is the collection of debts.<ref>https://www.consumerfinancialserviceslawmonitor.com/wp-content/uploads/sites/501/2019/02/Barbato-v-Crown.pdf {{Bare URL PDF|date=March 2022}}</ref> ==Prohibited conduct== The Act prohibits certain types of "abusive and deceptive" conduct when attempting to collect debts, including the following: * '''Hours for phone contact''': contacting consumers by telephone outside of the hours of 8:00 a.m. to 9:00 p.m. local time. Additionally, if certain hours are inconvenient for consumers during the allowable time (those who work at night and sleep during the day) they may not be contacted during those times.<ref>{{usc|15|1692c}}(a)(1)</ref> * '''Failure to cease communication upon request''': communicating with consumers in any way (other than litigation) after receiving ''written'' notice that said consumer wishes no further communication or refuses to pay the alleged debt, with certain exceptions, including advising that collection efforts are being terminated or that the collector intends to file a lawsuit or pursue other remedies where permitted.<ref>{{usc|15|1692c}}(c)</ref> * '''Causing a telephone to ring or engaging any person in telephone conversation repeatedly or continuously''': with intent to annoy, abuse, or harass any person at the called number.<ref name="usc|15|1692d">{{usc|15|1692d}}</ref> * '''Communicating with consumers at their place of employment''' after having been advised that this is unacceptable or prohibited by the employer.<ref>{{usc|15|1692c}}(a)(3)</ref> * '''Contacting a consumer known to be represented by an attorney'''. The collector must contact the attorney instead, unless the attorney is unresponsive or consents to the client's being contacted directly.<ref>{{usc|15|1692c}}(a)(2)</ref> * '''Communicating with a consumer after a request for validation has been made''': communicating with the consumer or pursuing collection efforts by the debt collector ''after'' receipt of a consumer's written request for verification of a debt made within the 30-day validation period (or for the name and address of the original creditor on a debt) and ''before'' the debt collector mails the consumer the requested verification or the original creditor's name and address.<ref name="usc|15|1692gb">{{usc|15|1692g}}(b)</ref> * '''Misrepresentation or deceit''': misrepresenting the debt or using deception to collect the debt, including a debt collector's misrepresentation that he or she is an attorney or law enforcement officer.<ref name="usc|15|1692e">{{usc|15|1692e}}</ref> * '''Publishing the consumer's name or address''' on a "bad debt" list.<ref>{{usc|15|1692}}(d)</ref> * '''Seeking unjustified amounts''', which would include demanding any amounts not permitted under an applicable contract or as provided under applicable law.<ref>{{usc|15|1692f}}(1); ''Hodges v. Sasil Corp., 915 A.2d 1'' (N.J. 2007)</ref> * '''Threatening arrest or legal action''' that is either not permitted or not actually contemplated.<ref name="usc|15|1692e"/> * '''Abusive or [[profanity|profane]] language''' used in the course of communication related to the debt.<ref name="usc|15|1692d"/> * '''Communication with third parties''': revealing or discussing the nature of debts with third parties (other than the consumer's spouse or attorney).<ref>{{usc|15|1692c}}</ref> (Debt collectors are allowed to contact neighbors or co-workers but only to obtain location information;<ref>{{usc|15|1692b}}</ref> disreputable agencies often harass debtors with a "block party" or "office party" where they contact multiple neighbors or co-workers telling them they need to reach the debtor on an urgent matter.<ref>{{cite book|title=The Fair Debt Collection Practices Act : hearing before the Subcommittee on Consumer Affairs and Coinage|date=10 September 1992|publisher=U.S. Government Printing Office|isbn=0-16-040760-5|page=12|url=https://catalog.hathitrust.org/Record/007604221|access-date=16 June 2017}}</ref>) * '''Contact by embarrassing media''', such as communicating with a consumer regarding a debt by post card, or using any language or symbol, other than the debt collector’s address, on any envelope when communicating with a consumer by use of mail or by telegram, except that a debt collector may use his business name if such name does not indicate that he is in the debt collection business.<ref>{{usc|15|1692f}}(8)</ref><ref>{{usc|15|1692f}}(7)</ref> * '''Reporting false information on a consumer's [[credit report]]''' or threatening to do so in the process of collection.<ref>{{usc|15|1692e}}(8)</ref> ==Required conduct== The Act requires debt collectors to do the following (among other requirements): * '''Identify themselves and notify the consumer''', in every communication, that the communication is from a debt collector, and in the initial communication that any information obtained will be used to effect collection of the debt.<ref name="usc|15|1692e"/> * '''Give the name and address of the original creditor''' (company to which the debt was originally payable) upon the consumer's written request made within 30 days of receipt of the §1692g notice.<ref name="usc|15|1692gb"/> * '''Notify the consumer of their right to dispute the debt (Section 809)''', in part or in full, with the debt collector. The 30-day "§1692g" notice is required to be sent by debt collectors within five days of the initial communication with the consumer, though in 2006 the definition of "initial communication" was amended to exclude "a formal pleading in a civil action" for purposes of triggering the §1692g notice,<ref>{{usc|15|1692g}}(d)</ref> complicating the matter where the debt collector is an attorney or law firm. The consumer's receipt of this notice starts the clock running on the 30-day right to demand verification of the debt from the debt collector.<ref name="usc|15|1692gb"/> * '''Provide [[Debt validation|verification of the debt]]'''.<ref>{{usc|15|1692g}}(a)(4)</ref> If a consumer sends a written dispute or request for verification within 30 days of receiving the §1692g notice, then the debt collector must either mail the consumer the requested verification information or cease collection efforts altogether. Such asserted disputes must also be reported by the creditor to any [[credit bureau]] that reports the debt. Verification should include at a minimum the amount owed and the name and address of the original creditor.<ref name="usc|15|1692gb"/> * '''File a [[lawsuit]] in a proper [[Venue (law)|venue]]'''. If a debt collector chooses to file a lawsuit, it may only be in a place where the consumer lives or signed the contract.<ref>{{usc|15|1692i}}</ref> Note, however, that this does not prevent the debt collector from ''being'' sued in other venues for violating the Act, such as when the consumer moves outside the venue and a letter demanding payment is forwarded to the new address, even if the debt collector is unaware of such a change in residence.<ref>{{cite web|title=Bates v. C & S Adjusters, Inc., 980 F.2d 865 (1992)|url=https://scholar.google.com/scholar_case?case=16670214372568573029|website=Google Scholar|access-date=16 June 2017}} (reasoning that bill collectors can mark envelopes "do not forward".)</ref> ==Enforcement of the FDCPA== The [[Federal Trade Commission]] originally had the authority to administratively enforce the FDCPA using its powers under the [[Federal Trade Commission Act]].<ref>{{usc|15|1692l}}</ref> However, under the sweeping reforms of the 2010 Dodd-Frank Act, the FDCPA is enforced primarily by the [[Consumer Financial Protection Bureau]].<ref>{{cite web|title=Debt collection|url=https://www.consumerfinance.gov/consumer-tools/debt-collection/|website=Consumer Financial Protection Bureau|access-date=16 June 2017}}</ref> Aggrieved consumers may also file a private lawsuit in a state or federal court to collect damages (actual, statutory, attorney's fees, and court costs) from third-party debt collectors. The FDCPA is a [[strict liability]] law, which means that a consumer need not prove actual damages in order to claim [[statutory damages]] of up to $1,000 plus reasonable attorney fees if a debt collector is proven to have violated the FDCPA.<ref>{{usc|15|1692k}}(a)(2)</ref> The collector may, however, escape penalty if it shows that the violation (or violations) was unintentional and the result of a "[[bona fide]] error" that occurred despite procedures designed to avoid the error at issue.<ref>{{usc|15|1692k}}(c)</ref><ref>{{cite court|litigants=Johnson v. Riddle |vol=443 |reporter=F.3d |opinion=723 |court=10th Cir. |date=2006 |url=http://ca10.washburnlaw.edu/cases/2006/04/04-4036.htm}}</ref> Alternatively, if the consumer loses the lawsuit and the court determines that the consumer filed the case in bad faith and for the purposes of harassment, the court may then award attorney's fees to the debt collector. Another limitation is the one year [[statute of limitations]], which the Supreme Court ruled in ''[[Rotkiske v. Klemm]]'' (2019) starts tolling from the date of the alleged violation, not from the date the incident was discovered.<ref>{{cite court|litigants=Rotkiske v. Klemm |vol=589 |reporter=US |opinion=10-328 |court=Supreme Court |date=2019 |url=https://www.supremecourt.gov/opinions/19pdf/18-328_pm02.pdf}}</ref> ==Criticisms of the FDCPA== ===By consumer groups=== Some consumer groups argue that the FDCPA does not go far enough, and does not provide sufficient deterrence against unscrupulous collection agencies. Consumer groups have complained that the maximum statutory damages contained in the original 1977 version of the law has not kept up with inflation;{{citation needed|date=July 2022}} $1,000 in 1977 dollars is worth ${{Inflation|US|1000|1977|r=0}} as of {{Inflation/year|US}}.{{Inflation-fn|US}} ===By the credit industry=== Conversely, many in the credit industry and some courts have taken the stance that the FDCPA has often been used to file frivolous lawsuits and seek damages for minor technical violations and has, at times, seriously impeded their ability to collect valid debts.<ref>{{cite web|title=Courts, Congress send mixed messages to debt collectors|url=http://www.nh.com/apps/pbcs.dll/article?AID=/20070720/BUSINESSREVIEW05/70718029|website=New Hampshire Business Review|archive-url=https://web.archive.org/web/20090214024034/http://www.nh.com/apps/pbcs.dll/article?AID=%2F20070720%2FBUSINESSREVIEW05%2F70718029|archive-date=14 February 2009|date=20 July 2007|url-status=dead}}</ref><ref>{{cite web|title=O'Connor v. Check Rite, Ltd., 973 F.Supp. 1010 (D. Colo. 1997)|url=https://scholar.google.com/scholar_case?case=14892481683081390004|website=Google Scholar|access-date=16 June 2017}} (awarding plaintiff statutory damages of only $0.01, and then finding plaintiff liable for a defendant’s attorneys’ fees and costs because of the plaintiff’s lack of discretion in filing the action)</ref> Given the strict liability nature of the FDCPA, the collections industry and the insurance companies that provide liability coverage for them have repeatedly lobbied Congress to relax provisions of the law to reduce their civil exposure for these "hyper-technical" violations.<ref>''Bailey v. Security Nat. Servicing Corp.,'' 154 F.3d 384 (C.A.7 (Ill.), 1998); ''Carroll v. Wolpoff & Abramson'', 53 F.3d 626 (C.A.4 (Md.), 1995)</ref> The [[accounts receivable]] management industry has also raised concerns that the FDCPA contains contradictions that often lead to liability on the part of collection agencies in civil cases, especially when dealing with technology that did not exist when the law was written. For example, the FDCPA requires a [[collection agency]] to identify itself as such in any communication with a consumer. At the same time, a collection agency cannot disclose the debt of a consumer to anyone else. These two requirements are at odds when a collector leaves a message on an answering machine or voicemail system. If the collector identifies himself and his company, a third party could hear the message, thus resulting in a third party disclosure violation. Case law has tackled this issue but has not yet resolved it.<ref>{{cite journal | title=Legal Ruling Further Muddies Waters on Third-Party Disclosure vs. Mini-Miranda | website=insideARM.com |date=Dec 12, 2008 | url=http://www.insidearm.com/daily/debt-collection-news/debt-collection/legal-ruling-further-muddies-waters-on-third-party-disclosure-vs-mini-miranda|access-date=2010-08-11}}</ref> ==Regulatory agencies and the FDCPA== For its part, the [[Federal Trade Commission]] (FTC) produces an annual report to Congress of its findings with respect to its FDCPA enforcement activities. This report details consumer complaints to the FTC about alleged debt collector violations of the FDCPA. The 2013 report indicated that the FTC received 125,136 consumer complaints about third party debt collectors in 2012, which is a decrease from the 144,451 received in 2011.<ref>{{cite web|title=FTC Letter to Hon. Richard Cordray|url=https://www.ftc.gov/system/files/documents/reports/federal-trade-commission-enforcement-fair-debt-collection-practices-act-report-consumer-financial/140305debtcollectionletter.pdf|website=Federal Trade Commission|access-date=16 June 2017|date=21 February 2014}}</ref> The FTC receives more complaints about debt collectors than about any other specific industry, though the number of complaints represents a small percentage of the overall number of contacts by debt collectors with consumers.<ref>{{cite web |url=http://files.consumerfinance.gov/f/201303_cfpb_March_FDCPA_Report1.pdf|title=Federal Trade Commission Annual Report 2013; Fair Debt Collection Practices Act|access-date=2013-11-06|publisher=Federal Trade Commission}}</ref> The FTC has authority to issue formal opinions regarding debt collectors' conduct under the FDCPA,<ref>See 16 CFR Ch. 1, Subpart A</ref> but the Dodd-Frank Wall Street Reform and Consumer Protection Act transfers authority for rule making to the new [[Consumer Financial Protection Bureau]] (CFPB) effective between January 21, 2011 and July 21, 2011. The FTC will retain FDCPA enforcement authority, but the CFPB will take over the FTC's advisory opinion function. Good faith conformity with a formal opinion of the FTC constitutes a second statutory defense under the FDCPA.<ref>15 U.S.C. 1692k(e)</ref> The FTC has only rarely exercised its authority to issue advisory opinions, however.<ref name="ftc.gov">See {{cite web|title=The Fair Debt Collection Practices Act|url=https://www.ftc.gov/enforcement/rules/rulemaking-regulatory-reform-proceedings/fair-debt-collection-practices-act-text|website=Federal Trade Commission|date=12 August 2013 |access-date=2 January 2018}}</ref> Prior to 2000, the FTC had not issued any advisory opinions regarding the FDCPA, it has issued only four such opinions through 2009.<ref name="ftc.gov"/> In March 2021, the CFPB issued its annual report to Congress on its implementation of the FDCPA. The bureau had participated in four actions against alleged FDCPA violations. Two of the cases were resolved with over $15 million in redress. The bureau also offered information to assist consumers through the COVID-19 pandemic, data on debt collection activity for student loans, and conducted an 8,000-respondent survey to test disclosures explaining time-barred debt and its rules on debt collection.<ref>{{cite web |last1=Clark |first1=Douglas |title=CFPB report examines Fair Debt Collection Practices Act |url=https://financialregnews.com/cfpb-report-examines-fair-debt-collection-practices-act/ |website=Financial Regulation News |date=24 March 2021 |publisher=Macallan Communications |location=Washington DC}}</ref> ==See also== *[[Consumer protection]] *[[Fair Credit Reporting Act]] *[[Consumer Credit Protection Act]] *[[Debt buyer]] == References == {{Reflist|2}} == External links == * [https://www.law.cornell.edu/uscode/text/15/chapter-41/subchapter-V As codified in 15 U.S.C. chapter 41] of the [[United States Code]] from the [[Legal Information Institute|LII]] * [https://uscode.house.gov/browse/prelim@title15/chapter41/subchapter5&edition=prelim As codified in 15 U.S.C. chapter 41] of the [[United States Code]] from the [[United States House of Representatives|US House of Representatives]] * [https://www.govinfo.gov/content/pkg/COMPS-260/uslm/COMPS-260.xml Fair Debt Collection Practices Act] ([https://www.govinfo.gov/content/pkg/COMPS-260/pdf/COMPS-260.pdf PDF]/[https://www.govinfo.gov/app/details/COMPS-260/ details]) as amended in the [[United States Government Publishing Office|GPO]] [https://www.govinfo.gov/help/comps Statute Compilations collection] *[https://www.ftc.gov/system/files/documents/plain-language/fair-debt-collection-practices-act.pdf Fair Debt Collection Practices Act] [[Federal Trade Commission]] *[http://www.fas.org/sgp/crs/misc/R43041.pdf Fair Debt Collection Practices Act (FDCPA)] [[Congressional Research Service]] *[http://www.naca.net National Association of Consumer Advocates] *[http://www.ftc.gov/os/statutes/fdcpajump.htm FTC's FDCPA Web Page] *[http://files.consumerfinance.gov/f/201503_cfpb-fair-debt-collection-practices-act.pdf CFPB 2015 FDCPA Report] {{Presidency of Jimmy Carter}} {{Bank regulation in the United States}} [[Category:1977 in American law]] [[Category:United States federal banking legislation]] [[Category:Debt collection]]
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