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FDCPA brain teaser


E. Normis Debtor
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Now that everyone has had time to digest the newly amended FDCPA, let me pose this question:

A CA decides to go right to litigation after being assigned an account rather than dunning.

They file a formal complaint it is sent to you with a summons.

Is this an initial communication triggering the requirement to inform you of your verification rights?

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We have a winner.

A summons is not a formal pleading, in fact it isn't a pleading at all; it is process.

The distinction between the two are clear. Courts ruling on the FDCPA have chosen to give the term "communication" a broad meaning, to include a summons. (There is also a FTC opinion in support of this.)

Though the intent of congress may have been otherwise, a court cannot look to intent when the plain meaning of the words are unambiguous; and they are.

My position is a summons is not exempt under the ammended FDCPA, it is a communication, and if it's the initial communication it triggers the requirement to inform a consumer of their verification rights.

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A summons is not a legal pleading, yes? The actual complaint is.

Funny thing, when I filed one case, they asked if I wanted the summons then and there. I wondered why I wouldn't (but then found out when I faxed a copy of the pleading sans summons to the defendant and got a settlement fairly quickly).

Filing isn't communicating with the debtor. A summons would be.

(Even if a summons were excluded, stuff later in the process, such as a request for admissions, would be a communication.)

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