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OC debt collector sometimes?

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I have a question about this definition in the FDCPA:

(4) The term "creditor" means any person who offers or extends credit creating a debt or to whom a debt is owed, but such term does not include any person to the extent that he receives an assignment or transfer of a debt in default solely for the purpose of facilitating collection of such debt for another.

Wouldn't this include one affiliate passing, by contract, a debt in default to another affiliate for collection?

A good example is Citigroup. There are several affilates under this OC; Citifinancial, Citibank, Citigroup Credit Services, etc., each being an OC itself. If Citigroup Credit Services receives a defaulted account from Citibank for the purposes of collection - and for that reason only - wouldn't CCS be a debt collector under the above definition and be bound by the FDCPA?

Another question is whether CCS is actually a debt collection affiliate of Citigroup in which CCS only collects debts for Citigroup. If this is the case then wouldn't CCS, by definition, be a debt collector since this is the purpose of its existence?

I bring this up because there is an exemption for affiliates collecting each other's debt, but this is only if the principal business of such person (affiliate) is not the collection of debts:

The term (debt collector) does not include:

(B) any person while acting as a debt collector for another person, both of whom are related by common ownership or affiliated by corporate control, if the person acting as a debt collector does so only for persons to whom it is so related or affiliated and if the principal business of such person is not the collection of debts;

If it is a fact that CCS, in this case, only collects debts (even if only for its affiliates) then CCS is a debt collector.

What does anyone think?

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