In the FTC’s 2014 annual letter to the CFPB summarizing the FTC’s debt collection activities, the FTC describes the CFPB as a “valuable partner” with whom the FTC anticipates an “even stronger [partnership] in the future.” The letter includes a discussion of the FTC’s collaboration with the CFPB on several amicus briefs in cases involving FDCPA issues, specifically Delgado and Buchanan dealing with the collection of time-barred debts and Hernandez dealing with the requirements for a collector’s “initial communication.” The letter also indicates that the FTC has been consulting with the CFPB in connection with the CFPB’s expected debt collection rulemaking.
The letter’s centerpiece is the FTC’s description of its “aggressive law enforcement activities” in the debt collection arena. The FTC states that in 2014, it filed 10 new cases against 56 new defendants, resolved 9 cases and obtained nearly $140 million in judgments, and banned 47 companies and individuals “that engaged in serious and repeated violations of law from ever working in debt collection again.” The letter highlights cases in which the FTC was successful in obtaining judgments or injunctive relief that involved (1) deceptive, unfair or abusive collector conduct generally, (2) abusive collection practices targeting Spanish-speaking consumers, (3) phantom debt collection, and (4) debt brokering and consumer data integrity.