Answer:
Sections of the new FDCPA define actions as being unfair or deceptive. Sound familiar? That tells me a violation of the FDCPA can also be a UDAP/UDAAP violation, which you are subject to. Plus, many banks outsource some collection activity. While the bank can delegate authority to collect a debt, it still has the responsibility to ensure rules are followed.
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Learn more about Andy Zavoina’s Common Compliance Violations and Hot Topics webinar.