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FTC opinion legality written into FDCPA

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15 U.S.C. §1692k(e) states that:

No provision of this section imposing any liability shall apply to any act done or omitted in good faith in conformity with any advisory opinion of the [FTC], notwithstanding that after such act or omission has occurred, such opinion is amended, rescinded, or determined by judicial or other authority to be invalid for any reason.

Formal advisory opinions for purposes of this provision are not:

1. informal staff letters;

2. FTC commentary to the FDCPA; or

3. an FTC formal advisory opinion on issues addressed in staff commentary when the staff commentary was incomplete.

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