Consumer Finance Litigation

In a case of first impression, the Eleventh Circuit recently held that a voicemail constitutes a "communication" under the FDCPA, and can thus trigger the mini-Miranda requirement, but an individual collecting on behalf of a debt collector is not required to disclose his or her identity in order to comply with the "meaningful disclosure" requirement under the FDCPA.

In Hart v. Credit Control, LLC, ___ F.3d ___, 2017 WL 4216029 (11th Cir. 2017), Plaintiff Stacey Hart filed suit alleging that Credit Control, LLC's voicemail violated § 1692e(11) of the FDCPA by failing to include the ...