Seventh Circuit in Boucher: Miller Safe Harbor Language Does Not “Immunize” Debt Collectors from Liability for Violations of § 1692e
Consumer Financial Services Law
FEBRUARY 11, 2018
By Zachary K. Dunn Eighteen years ago, the Seventh Circuit crafted “safe harbor” language which, if used, shielded debt collectors from liability under 15 U.S.C. § 1692g. A recent decision, Boucher v. Fin. Sys. of Green Bay , 2018 U.S. App. LEXIS 1094 (7th Cir. 2018) , now calls that safe harbor language into question and subjects collectors to liability under another section of the Fair Debt Collection Practices Act (“FDCPA”), § 1692e, for use of the language the court itself drafted.
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