15 U.S.C. § 1692h
Multiple debts
If any consumer owes multiple debts and makes any single payment to any debt collector with respect to such debts, such debt collector may not apply such payment to any debt which is disputed by the consumer and, where applicable, shall apply such payment in accordance with the consumer’s directions.
Notes of Decisions
Cited in 11
cases (4 in the last 5 years), 1991–2026 · leading case: McDermott v. Marcus, Errico, Emmer & Brooks, P.C., 911 F. Supp. 2d 1 (D. Mass. 2012).
McDermott v. Marcus, Errico, Emmer & Brooks, P.C., 911 F. Supp. 2d 1 (D. Mass. 2012). “15 U.S.C. § 1692h. The section also requires the debt collector to apply “payments] in accordance with the consumer’s direction.”
Rita Camacho, on Behalf of Herself & All Others Similarly Situated v. Bridgeport Fin. Inc., & Ray Lewis, Christina Harbridge, 430 F.3d 1078 (9th Cir. 2005). “15 U.S.C. § 1692h. Moreover, a debtor’s oral notification to a debt collector entitles a debtor to relief under § 1692c(a)(l), which bars communication with a debtor at “a time or place known or which should be known to be inconvenient to the consumer.”
McDermott v. Marcus, Errico, Emmer & Brooks, P.C., 775 F.3d 109 (1st Cir. 2014). “” He then told the magistrate judge that MEEB violated these two statutes when it engaged in a convoluted collection procedure which inevitably caused mis-communication, lack of communication, confusion, and acrimony that escalated litigation costs and served as a pretext for…”
Jerman v. Carlisle, McNellie, Rini, Kramer & Ulrich, 464 F. Supp. 2d 720 (N.D. Ohio 2006). “15 U.S.C. § 1692h. Moreover, a debtor’s oral notification to a debt collector entitles a *725 debtor to relief under § 1692c(a)(l), which bars communication with a debtor at ‘a time or place known or which should be known to be inconvenient to the consumer.”
Credit One, LLC v. Head, 977 A.2d 767 (Conn. App. Ct. 2009). “In his appellate brief, the defendant refers, without providing any legal analysis, to 15 U.S.C. § 1692h (a) (4) and two federal cases addressing what constitutes acceptable debt collection means under that act.”
Graziano v. Harrison, 763 F. Supp. 1269 (D.N.J. 1991). “The section does provided that the debt collector may apply the payment "in accordance with the debtor’s directions”, 15 U.S.C. § 1692h, but handling multiple debts as consolidated upon a debtor’s instruction does not indicate how a debt collector should treat them initially.”
Davis v. Bridgecrest Acceptance Corp. (W.D. Mo. 2022). “§ 1692f; “Multiple Debts” under 15 U.S.C. § 1692h; and “Furnishing certain deceptive forms” under 15 U.”
(PS) Narayan v. Cnty. of Sacramento (E.D. Cal. 2022). “12 at 1); FDCPA 25 § 809, 15 U.S.C. § 1692h (validation of debts) (id.”
Crow v. Stenger & Stenger P.C. (S.D. Ohio 2025). “) 1 Crow mistakenly alleged that Defendants violated 15 U.S.C. § 1692h, but § 1692g is the provision that requires debt collectors to validate debts upon request of the purported debtor.”
Garcia v. Auto Nation North (Colo. Ct. App. 2026). “Comm’n 2022); the Fair Debt Collection Practices Act, 15 U.S.C. § 1692h; the Securities Exchange Act of 1934, 15 U.”
Camacho v. Bridgeport Fin. (9th Cir. 2005). “15 U.S.C. § 1692h. Moreover, a debtor’s oral notification to a debt collector entitles a debtor to relief under § 1692c(a)(1), which bars communication with a debtor at “a time or place known or which should be known to be inconvenient to the consumer.”
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