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Tag Archives: Ellis v. Solomon and Solomon

Exercise Care When Suing Debtors During the FDCPA Validation Period

Posted in Fair Debt Collection Practices Act

Filing a collection lawsuit during the 30-day debt validation period can get a collector in hot water unless he is really careful. The United States Court of Appeals for the Second Circuit recently decided a case where Citibank hired a law firm to collect Janet Ellis’s alleged credit card debt. The law firm, Solomon & Solomon, promptly sent the FDCPA required notice advising her of the debt and informing her that she had 30 days in which to dispute its validity. Otherwise the firm would assume the debt was valid. So far, so good.

The Fair Debt Collection Practices Act requires that within five days of its initial communication with a consumer, a debt collector must send a written “validation notice” setting forth the consumer’s right to dispute the debt. The consumer then has 30 days in which to send a notice to the debt collector that he disputes. During this 30-day period, the debt collector generally is free to continue collection activities so long as they do not “overshadow” or are not “inconsistent” with the disclosures in the validation notice.

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Second Circuit: Lawsuit During FDCPA Validation Period Overshadows Notice

Posted in Fair Debt Collection Practices Act

A recent case out of Connecticut waves a yellow flag at debt collectors who file lawsuits within 30 days of sending a consumer a validation notice under the Fair Debt Collections Practices Act (“FDCPA”). On January 13, 2010, the Second Circuit Court of Appeals held that a law firm and two of its lawyers violated the FDCPA, 15 U.S.C. § 1692 et. seq., when it filed suit against a debtor during the 30-day validation period without providing additional explanation to the debtor about how the lawsuit affected the notice. Ellis v. Solomon and Solomon, P.C., et. al., No. 09-1247-cv (2d Cir. Jan. 13, 2010).

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