On January 9, 2017, the Consumer Financial Protection Bureau (CFPB) announced that it entered into a consent order with two affiliated medical debt collection law firms over allegations that the law firms used deceptive collection letters and illegally notarized collection affidavits. The consent order alleges that the law firms would send debtors collection notices purporting to be from an attorney or law firm even though no attorney or law firm had reviewed the consumer’s account. The debt collection firm made similar representations in telephone calls, implying that an attorney was involved in the dispute even though no attorney determined that a consumer’s debt was valid or that a lawsuit against the consumer would have been an appropriate remedy. The consent order also alleged that the law firms notarized signatures without verifying their accuracy, and failed to implement adequate quality control procedures to ensure the accuracy of information it provided to credit reporting agencies about over one million consumers, in violation of the Fair Credit Reporting Act. The consent order requires the law firms to return $577,135 to debtors, to discontinue their prior, unlawful practices, and to pay a civil monetary penalty of $78,800.
