This note discusses the circuit split that is found regarding whether the FDCPA applies to communications from a debt collector to a debtor's attorney between the Third, Fourth, Seventh and Tenth Circuits. The Third, Fourth and Seventh Circuits have found that the FDCPA applies to communications with attorneys (at least under some circumstances), whereas the Tenth Circuit has applied a categorical exclusion for communications to attorneys.
This article can be found here:
http://papers.ssrn.com/sol3/papers.cfm?abstract_id=1830597
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