15 U.S.C. § 1692j

Furnishing certain deceptive forms

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(a) It is unlawful to design, compile, and furnish any form knowing that such form would be used to create the false belief in a consumer that a person other than the creditor of such consumer is participating in the collection of or in an attempt to collect a debt such consumer allegedly owes such creditor, when in fact such person is not so participating.(b) Any person who violates this section shall be liable to the same extent and in the same manner as a debt collector is liable under section 1692k of this title for failure to comply with a provision of this subchapter.(Pub. L. 90–321, title VIII, § 812, as added Pub. L. 95–109, Sept. 20, 1977, 91 Stat. 880.)Statutory Notes and Related SubsidiariesEffective Date

Section effective upon the expiration of six months after Sept. 20, 1977, see section 819 of Pub. L. 90–321, as added by Pub. L. 95–109, set out as a note under section 1692 of this title.

Notes of Decisions
Cited in 87 cases (41 in the last 5 years), 1981–2026 · leading case: Michelle Echlin v. Peacehealth, 887 F.3d 967 (9th Cir. 2018).
Michelle Echlin v. Peacehealth, 887 F.3d 967 (9th Cir. 2018). · cites it 4× “II Echlin first argues that the district court erred in granting summary judgment against her flat-rating claim that CCI’s letters “created a false or misleading belief that Defendant CCI was meaningfully involved in the collection of [her] debt prior to the debt actually being…”
Vincent v. The Money Store, 736 F.3d 88 (2d Cir. 2013). · cites it 4× “In addition, although not asserted by plaintiffs, there would have likewise been a triable claim as to whether Moss Codilis violated 15 U.S.C. § 1692j, which prohibits: [T]he practice commonly known as “flat-rating,” in which an individual sends a delinquency letter to the…”
Hartley v. Suburban Radiologic Consultants, Ltd., 295 F.R.D. 357 (D. Minnesota 2013). · cites it 7× “Specifically, Hartley claims that (1) the letter constitutes a flat-rating scheme in violation of 15 U.S.C. § 1692j, which prohibits a creditor from creating the false impression that a debt collector is involved in the collection of a creditor’s debts, when in fact a third…”
Taylor v. Perrin, Landry, deLaunay & Durand, 103 F.3d 1232 (5th Cir. 1997). · cites it 4× “15 U.S.C. § 1692j(a). Any person who violates this section shall be liable to the same extent and in the same manner as a debt collector is liable for failure to comply with a provision of the Act.”
Francis Gutierrez & Joseph Rydel v. At&t Broadband, LLC & Commc'ns & Cable of Chicago, Inc., 382 F.3d 725 (7th Cir. 2004). · cites it 3× “See 15 U.S.C. § 1692j. 2. Customer Notice The second document that allegedly draws Corporate Broadband under § 1692j is titled “Important Notices to Our Customers.”
Dennis Dixon v. Stern & Eisenburg PC, 652 F. App'x 128 (3rd Cir. 2016). · cites it 3× “15 U.S.C. § 1692j. Dixon’s complaint invokes all of these subsections.”
Rumpler v. Phillips & Cohen Assocs., Ltd., 219 F. Supp. 2d 251 (E.D.N.Y 2002). · cites it 4× “) Finally, Rumpler alleges that P & C violated 15 U.S.C. § 1692j by purportedly “creating a deceptive form knowing that such form would be used to create the false belief in a consumer that a person other than the creditor of such consumer is participating in the collection of…”
Sokolski v. Trans Union Corp., 53 F. Supp. 2d 307 (E.D.N.Y 1999). · cites it 7× “The FDCPA prohibits flat-rating and makes it unlawful to furnish any form used to create a false belief that a third party is involved in the collection of a debt, 15 U.S.C. § 1692j, because of the practice’s “inherently deceptive” impression that there is a third party engaged…”
Johnson v. Statewide Collections, Inc., 778 P.2d 93 (Wyo. 1989). · cites it 4× “Whether the debt collector violated 15 U.S.C. § 1692j and/or acted in bad faith by failing to give notification to the alleged debtor that the debt collector was not in fact the true holder of the instrument' after it had represented that it was and was authorized to attempt to…”
Harrison v. NBD INC., 968 F. Supp. 837 (E.D.N.Y 1997). · cites it 3× “The Vernon court stated that “[a]n even more fundamental reason for denying this part of the motion to dismiss is that the plaintiff does allege that Beneficial participated in acts which violated 15 U.S.C. § 1692j.” Id. at 3 (emphasis in original).”
Christ Clomon v. Philip D. Jackson, 988 F.2d 1314 (2d Cir. 1993). “Jackson argued (1) that he never violated 15 U.S.C. § 1692j, which forbids the use of forms that create the false impression that anyone other than the creditor is involved in the collection effort, and (2) that he did not violate the FDCPA in sending collection notices to…”
Littles v. Lieberman, 90 B.R. 700 (E.D. Pa. 1988). · cites it 4× “I will discuss below my reasons for finding that defendant Lieberman was a supplier of a deceptive form within the meaning of FDCPA, 15 U.S.C. § 1692j. For the purpose of determining the effect of the Fleet Settlement, it is sufficient to state that I so find.”
— 15 U.S.C. § 1692j(a) — 40 cases
Michelle Echlin v. Peacehealth, 887 F.3d 967 (9th Cir. 2018). “II Echlin first argues that the district court erred in granting summary judgment against her flat-rating claim that CCI’s letters “created a false or misleading belief that Defendant CCI was meaningfully involved in the collection of [her] debt prior to the debt actually being…”
Taylor v. Perrin, Landry, deLaunay & Durand, 103 F.3d 1232 (5th Cir. 1997). “15 U.S.C. § 1692j(a). Any person who violates this section shall be liable to the same extent and in the same manner as a debt collector is liable for failure to comply with a provision of the Act.”
Francis Gutierrez & Joseph Rydel v. At&t Broadband, LLC & Commc'ns & Cable of Chicago, Inc., 382 F.3d 725 (7th Cir. 2004). “See 15 U.S.C. § 1692j. 2. Customer Notice The second document that allegedly draws Corporate Broadband under § 1692j is titled “Important Notices to Our Customers.”
Ann L. Nielsen v. David D. Dickerson, 307 F.3d 623 (7th Cir. 2002).
Frye v. Bowman, Heintz, Boscia & Vician, Pc, 193 F. Supp. 2d 1070 (S.D. Ind. 2002).
— 15 U.S.C. § 1692j(b) — 3 cases
Taylor v. Perrin, Landry, deLaunay & Durand, 103 F.3d 1232 (5th Cir. 1997). “15 U.S.C. § 1692j(a). Any person who violates this section shall be liable to the same extent and in the same manner as a debt collector is liable for failure to comply with a provision of the Act.”
Gallaher v. Estates at Aloma Woods Homeowners Ass'n, Inc., 316 F. Supp. 3d 1358 (M.D. Fla. 2018).
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