FYI: 6th Cir Holds Debt Buyer Violated FDCPA by Requesting Interest on Charged-Off Debt in Its Collection Complaint

The U.S. Court of Appeals for the Sixth Circuit recently held that a debt buyer’s request for interest on a charged-off credit card debt in its prayer for relief in its collection complaint were illegal under state law, and violated the federal Fair Debt Collection Practices Act (“FDCPA”).

 

A copy of the opinion is available at: http://www.ca6.uscourts.gov/opinions.pdf/14a0266p-06.pdf

 

In December 2008, after the debtor stopped making payments on her credit card, the creditor determined that the debt was uncollectible, ceased charging interest on the debt, and “charged off” the $2,630.95 debt.  A little over a year later, the creditor sold off its interest in the charged-off debt to a debt buyer (“debt collector”).

 

Two years later, the debt collector brought suit against the debtor seeking the $2,630.95 balance, plus interest accrued after the charge-off at the rate of 8% per annum —the default rate set by Kentucky’s usury statute—rather than the 21.99% rate established under the initial credit agreement.

 

The debtor responded by filing a class action lawsuit against the debt collector, alleging that the debt collector’s collection lawsuit violated the FDCPA as: (i) an attempt to collect unauthorized interest; (ii) a false representation of the character of the debt, and (iii) a threat to take action that cannot legally be taken.  See 15 U.S.C. § 1692f(1), § 1692e(2)(A) and § 1692e(5).

 

The lower court dismissed the debtor’s class action suit, holding that “[t]he state court collection action was a lawful vehicle for [the debt collector] to recover the debt,” as the state’s usury statute permitted prejudgment interest, and the allegation within the debt collector’s collection complaint was merely a request, rather than a false representation or threat.

 

On appeal to the Sixth Circuit, the questions before the Court were: (i) whether the original creditor’s waiver of its right to contractual interest gives it, or the debt collector, the right to collect statutory interest; and  (ii) whether the debt collector’s complaint falsely represented the character and amount of the debt, in violation of the FDCPA.

 

Kentucky’s usury statute states that any assignee “shall be bound for such rate of interest as is expressed in any such.. assumption” and that “no law of this state prescribing.. interest rates shall apply to any such agreement or to any charges which pertain thereto.”  See Ky. Rev. Stat. § 360.010(1).

 

Applying Kentucky’s usury statute, the Sixth Circuit held that nothing in the statute suggests that a contracting party retains the option to charge statutory interest.  Here, the right to collect statutory interest was extinguished and superseded by the right to collect interest at a rate specified by contract.

 

Thus, the Sixth Circuit held that the original creditor’s waiver of its right to collect contractual interest did not permit the debt collector to recover statutory interest that was bargained away.

 

Next, the Court was asked to determine if the allegations within the debt collector’s complaint rose to violations of the FDCPA.

 

As you may recall, the FDCPA prohibits both “false, deceptive, or misleading representations or means in connection with the collection of any debt,” 15 U.S.C. § 1692e; and “unfair practices”—“unfair or unconscionable means to collect or attempt to collect any debt,” id. § 1692f.

 

The Sixth Circuit acknowledged that the FDCPA has a broad and expansive purpose that the Supreme Court has held “applies to the litigating activities of lawyers” and “imposes some constraints to a lawyer’s advocacy.” Heintz v. Jenkins, 514 U.S. 291, 294 (1995); Jerman v. Carlisle, McNellie, Rini, Kramer & Ulrich LPA, 559 U.S. 573, 600 (2010).  Indeed, the FDCPA initially expressly exempted attorneys, but, in 1986 “Congress repealed this exemption in its entirety . . . without creating a narrower, litigation-related exemption to fill the void.” Id. at 294.

 

To determine whether the debt collector’s conduct violated the FDCPA, the Sixth Circuit considered the alleged violations through the lens of the “least sophisticated consumer” standard, the objective legal standard in FDCPA cases in the Sixth Circuit and other circuits.  Gionis v. Javitch, Block, Rathbone, LLP, 238 F. App’x 24, 28 (6th Cir. 2007).

 

Here, the Court rejected the debt collector’s argument that its allegation regarding the allegedly-owed interest was merely a “simple request,” because “even a sophisticated consumer would read that numbered paragraph from the complaint to be a factual allegation.”  The Sixth Circuit held, from the perspective of the least sophisticated consumer, that the request for statutory interest is a “threat.. to take action that cannot legally be taken,” i.e. attempt to collect recover interest that was not owed.

 

Accordingly, the Sixth Circuit that request for statutory interest in the debt collector’s collection complaint was an “attempt” to collect an “amount” that is neither “expressly authorized” by any agreement in the record nor “permitted by law.”   § 1692f(1). 

 

Accordingly, the Sixth Circuit reversed the district court’s order dismissing the debtor’s case, and remanded the matter to the district court for proceedings consistent with this opinion.

 

 

 

 

 

Ralph T. Wutscher
McGinnis Wutscher Beiramee LLP
The Loop Center Building
105 W. Madison Street, 18th Floor
Chicago, Illinois 60602
Direct: (312) 551-9320
Fax: (312) 284-4751
Mobile: (312) 493-0874
Email: RWutscher@mwbllp.com

 

Admitted to practice law in Illinois

 

 

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FYI: Ill App Ct Rules Trial Court Improperly Accepted Mortgagee's Affidavits in Support of Service By Publication, Improperly Rejected Borrower's Opposing Affidavits

The Illinois Appellate Court, First District, recently held that a mortgagee’s affidavits used to support service by publication against a borrower did not comply with Illinois and local county rules, and therefore that the borrower was not properly served, and the related judgment of foreclosure by default was improperly entered.

 

The Court also held that the trial court failed to properly consider the borrower’s affidavits when ruling on his motion to quash service by publication and motion to reconsider.

 

A copy of the opinion is available at:  http://www.state.il.us/court/Opinions/AppellateCourt/2014/1stDistrict/1133553.pdf

 

A borrower failed to make payments on his mortgage loan, and the mortgagee filed a complaint to foreclose mortgage.  The mortgagee moved to have special process servers appointed. 

 

Subsequently, the mortgagee’s counsel filed two affidavits to allow service by publication.  According to the Appellate Court, the first affidavit, filed pursuant to an Illinois statute on the subject, failed to specify what “diligent inquiry” had been made concerning the whereabouts of the borrower.  The later affidavit, filed pursuant to a local trial court rule, also according to the Appellate Court failed to specify what “diligent inquiry” had been made concerning the whereabouts of the borrower.

 

The mortgagee also filed two additional supporting affidavits.  The owner of a process-serving company filed the first supporting affidavit.  Generally, it stated that his employee searched for new addresses and new records concerning the borrower.

 

The second supporting affidavit, signed by the court-appointed special process server, stated that he was unable to effect service of the summons and complaint on the borrower.  Of note, his affidavit further stated that he went to the subject condominium three mornings during Memorial Day weekend, a phone (possibly an apartment building intercom) was disconnected, and an unspecified neighbor told him that the borrower went back to visit his family in Poland.  The latter affidavit also attached two pictures.  One picture showed the exterior of the apartment building, and the other showed the apartment building lobby.

 

The court allowed service by publication, and the mortgagee published a notice of the pending action in June and July 2010.  In May 2011, it filed a motion for entry of an order of default judgment and for foreclosure and sale against the borrower for failure to answer and appear.  On June 23, 2011, the trial court entered an order of default and judgment for foreclosure and sale against the borrower.

 

On August 18, 2011, a notice of sale was mailed to borrower at the condominium.  The borrower asserted that this was the first time that he became aware of the lawsuit.

 

The borrower filed a motion to quash service and to vacate the judgment for foreclosure.  He claimed that the service made by publication was invalid because he resided at the property and was not personally served.  He provided two affidavits stating that he had resided at the condominium since June 2007.  The affidavits also stated that one would have been able to view his possessions in the property and that a process server could have served him at another time.  The trial court denied the borrower’s motion to quash.

 

The borrower then filed a motion to reconsider and attached another affidavit.  He attached another affidavit which reflected that he had not attempted to conceal his whereabouts to leave the state or avoid litigation.  He further attested that he was Bulgarian, not Polish, and provided supporting documentation demonstrating that he lived at the condominium.  The trial court denied the borrower’s motion to reconsider, noting that the borrower’s two self-serving affidavits were not sufficient.  The trial court did not reference the borrower’s third affidavit or supporting documentation.

 

As you may recall, proper service is required for a court to obtain jurisdiction over the parties.  When a defendant has not been served with process as required by law, a court has no jurisdiction over that defendant and a default judgment against him is void.  See Equity Residential Properties Management Corp. v. Nasalo, 364 Ill. App. 3d 26, 32 (1st Dist. 2006).

 

The Appellate Court noted that Section 2-206 of the Illinois Code of Civil Procedure required a plaintiff requesting service by publication to file an affidavit showing that a defendant “on due inquiry cannot be found, or is concealed within this State, so that process cannot be served upon him or her, and stating the place of residence of the defendant, if known, or that upon diligent inquiry his or her place of residence cannot be ascertained[.]”  See 735 ILCS 5/2-206. 

 

In addition, the county in which the trial court sat (Cook County) adopted a rule elaborating on the requirement for the affidavit.  It requires that all affidavits for service of summons by publication be accompanied by a sworn affidavit by the individuals making such due inquiry, setting forth with particularity the action to demonstrate an honest and well directed effort to ascertain the whereabouts of the defendant, by inquiring as full as circumstances permit prior to placing any service of summons by publication.  See Cook. Co. Cir. Ct. R. 7.3. 

 

The Court placed particular emphasis on the Cook County Local Rule 7.3’s “honest and well-directed effort” requirement.  It criticized the process-server’s decision to attempt service three times over the course of Memorial Day weekend.  Nor did the process server try coming at alternative times during the day.  Further, the Court enumerated additional actions that the process server could have taken in order to determine whether the borrower lived at the condominium.  Accordingly, the Appellate Court held that service by publication was not justified, and any order entered by the trial court was void.

 

Next the Appellate Court turned to the borrower’s affidavits, as the borrower was required to show that he could have been found on due inquiry.  Employing a de novo standard of review, the Court concluded that the trial court erred in rejecting all three of the borrower’s affidavits.  The Court reasoned that if from consideration of the documents in their entirety, the affidavits appeared to satisfy Illinois Supreme Court Rule 191 because the affidavits were based upon the personal knowledge of the borrower, and there was a reasonable inference that the borrower could testify to the affidavits’ contents at trial.  See Doria v. Village of Downers Grove, 397 Ill. App. 3d 752, 795 (2d Dist. 2009).  Thus, the Appellate Court held that the borrower’s affidavits were sufficient to meet his burden of showing that he could have been found upon due inquiry.

 

Accordingly, the Appellate Court reversed and remanded the case to the trial court.

 

 

 

 

Ralph T. Wutscher
McGinnis Wutscher Beiramee LLP
The Loop Center Building
105 W. Madison Street, 18th Floor
Chicago, Illinois 60602
Direct: (312) 551-9320
Fax: (312) 284-4751
Mobile: (312) 493-0874
Email: RWutscher@mwbllp.com

 

Admitted to practice law in Illinois

 

 

          McGinnis Wutscher Beiramee LLP

CALIFORNIA    |  FLORIDA   |   ILLINOIS   |   INDIANA   |   WASHINGTON, D. C.

                                www.mwbllp.com

 

 

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FYI: CFPB Issues "Supervisory Highlights" (6th ed.) Noting Various Deficiencies In Mortgage Servicing, Debt Collection, Student Lending, Deposits, and Other Areas

The CFPB issued its sixth edition of its “Supervisory Highlights,” summarizing various observations from its examination process, including in the areas of consumer reporting, debt collection, deposits, mortgage servicing, and student loan servicing.

 

A copy of the Fall 2014 CFPB Supervisory Highlights is available at:  http://files.consumerfinance.gov/f/201410_cfpb_supervisory-highlights_fall-2014.pdf

 

As to mortgage servicing and debt collection in particular, the CFPB noted issues as to the following areas:

 

Mortgage Servicing:

 

•  Third Party and Vendor Management  (absence of policies and procedures, omission of some vendors required under Regulation X, absence of periodic review requirements, absence of specificity as to sharing of loss mitigation information)

•  Loan modifications (failures to timely convert trial mod into permanent mod while interest accrued and reported payments as late, terms of mod docs not matching terms approved by underwriting followed by corrected mod docs, steering borrower away from HAMP to proprietary mods)

•  Short sales (waivers of deficiency not confirmed in short sale agreements)

 

Debt Collection:

 

•  Unlawful imposition of convenience fees not allowed under state law, or not provided by agreement 

•  False threats of litigation 

•  Faulty training materials causing prohibited disclosures to third parties (faulty training materials directed employees to disclose their name and collector’s name parties before identifying the party with whom they were speaking, and without being expressly requested to do so)

•  Unfair practices with respect to debt sales (sellers overstating APRs in documents provided to debt buyers, significant delays by seller in transferring post-sale payments to debt buyers)

 

 

As to deposits and student loan servicing, the CFPB noted issues as to the following areas:

 

Student Loan Servicing:

 

•  Allocating partial payments in a way that maximizes late fees 

•  Misrepresentations about required minimum payments on billing statements

•  Charging improper late fees

•  “Out of Time” telephone communications

 

Deposits:

 

•  Violations of Regulation E error resolution requirements (including as to Notices)

•  Violations regarding Regulation E liability for unauthorized transfers

 

 

 

 

Ralph T. Wutscher
McGinnis Wutscher Beiramee LLP
The Loop Center Building
105 W. Madison Street, 18th Floor
Chicago, Illinois 60602
Direct: (312) 551-9320
Fax: (312) 284-4751
Mobile: (312) 493-0874
Email: RWutscher@mwbllp.com

 

Admitted to practice law in Illinois

 

 

          McGinnis Wutscher Beiramee LLP

CALIFORNIA    |  FLORIDA   |   ILLINOIS   |   INDIANA   |   WASHINGTON, D. C.

                                www.mwbllp.com

 

 

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FYI: Md Fed Ct Denies Servicer's Motion to Dismiss as to Multiple Successive Alleged QWRs, TILA Notice of Ownership Change, and Premature Foreclosure

The U.S. District Court for the District of Maryland recently denied motions to dismiss a borrower’s complaint against a mortgage loan servicer and the loan owner that alleged that the servicer and owner:

 

A.  Supposedly failed to notify the borrower of a transfer of ownership of the mortgage loan, and failed to answer inquiries concerning the owner of the loan, as required by the Truth in Lending Act, 15 U.S.C. § 1641(f)(2), (g) (“TILA”);

 

B.  Supposedly failed to respond to purported qualified written requests, as required by the Real Estate Settlement Procedures Act, 12 U.S.C. § 2605(e) (“RESPA”); and

 

C.  Supposedly threatened foreclosure despite supposedly knowing that no right to foreclose existed, as prohibited by Maryland’s Consumer Debt Collection Act, Md. Code Ann., Com. Law § 14-202(8) (“MCDCA”).

 

In denying the motion to dismiss the QWR allegations, the Court held that “[n]othing on the face of RESPA prevents a borrower from inundating his servicer with QWRs, even where the period to respond has not passed,” but also clarifying that “[i]n such a situation, presumably the servicer could satisfy the multiple requests in one response.” 

 

A copy of the opinion is attached.

 

The plaintiff borrower (“Plaintiff”) allegedly obtained a mortgage refinance loan in 2009 (“2009 Loan”).  The 2009 Loan was purportedly used to satisfy a prior 2008 loan (“2008 Loan”) extended by a different lender, and resulted in lower monthly payments than those due on the 2008 Loan.  At the time of the 2009 Loan, the lender supposedly failed to provide Plaintiff with a copy of the note, or any other closing documents, purportedly indicating that the loan’s servicer (“Servicer”) would send Plaintiff copies of the note and closing documents.  The Plaintiff also alleged that the lender of the 2009 Loan represented that it had no record of making the 2009 Loan. 

 

According to Plaintiff, Servicer continued to request payments on the 2008 Loan, which Plaintiff continued to make for a year after the purported 2009 Loan.  Plaintiff alleged that he contacted Servicer to request a copy of the note evidencing the 2009 Loan, and to inquire about why Servicer was still seeking payments on the 2008 Loan.  Plaintiff contended that Servicer was unresponsive.  At some point not included in the record, ownership of the 2008 Loan was transferred to the current loan owner (“Owner”).

 

In 2010, Plaintiff ceased making payments on the 2008 Loan, at which point Servicer began soliciting Plaintiff for a loan modification.  Plaintiff applied for several loan modifications over the next two years, but was unsuccessful. 

 

In May 2012, Plaintiff wrote to Servicer to request a payoff statement, a payment history, and a copy of the note.  In June 2012, the substitute trustees (“Substitute Trustees”) for the deed of trust securing the 2008 Loan (“2008 Deed of Trust”) sent Plaintiff a letter threatening to foreclose if he failed to pay off or reinstate the loan.  Servicer issued a Notice of Intent to Foreclose approximately three weeks later. 

 

Plaintiff then allegedly sent a second letter to Servicer, purportedly complaining that he received no response to his earlier May 2012 letter, and demanding the documents requested within ten days.  Plaintiff alleged that after not receiving any response to this second letter, he wrote a third letter in September 2012 requesting the identity of the owner of the 2008 Loan along with the documentation previously requested.  According to Plaintiff, Servicer ignored these requests.

 

Plaintiff alleged that nearly a year later, in August 2013, he sent additional correspondence seeking the identity of the owner of the 2008 Loan, and also requesting a copy of the note.  In response, Servicer sent a copy of the note and a loan payment history by separate letters approximately three weeks later. 

 

On August 16, 2013, the Substitute Trustees allegedly sent Plaintiff a letter stating that a foreclosure sale of the property may occur at any time forty-five days from the date of the letter.  Plaintiff was purportedly served with the foreclosure order to docket on August 28, 2013.  The foreclosure order identified Owner as “the owner or secured creditor” of the loan, and included a copy of the note that was indorsed to Servicer.

 

Plaintiff filed an action against Owner and Servicer (collectively, “Defendants”), among others, alleging that (1) Owner and Servicer violated TILA by supposedly failing to notify Plaintiff of the transfer of ownership of the 2008 Loan to Owner, and of an assignment of the 2008 Deed of Trust to Servicer, as required by 15 U.S.C. §1641(g); (2) Servicer violated TILA by supposedly failing to provide Owner’s name, address, and telephone number to Plaintiff upon request, as required by 15 U.S.C. § 1641(f)(2); (3) Servicer violated RESPA by supposedly failing to respond to Plaintiff’s purported qualified written requests, as required by 12 U.S.C.§ 2605(e); and (4) Owner and Servicer were vicariously liable under the MCDCA for Substitute Trustee’s actions of allegedly attempting to collect a debt with knowledge that the right does not exist, as prohibited by Md. Code Ann., Com. Law § 14-202(8).  The Defendants moved to dismiss Plaintiff’s claims.

 

As to the allegations that Servicer and/or Owner violated TILA by failing to notify Plaintiff of either the transfer of ownership of the loan to Owner, the Defendants argued that Plaintiff’s claim was time barred by TILA’s one year statute of limitations as to claims for money damages.  The Defendants contended that although the date of the alleged transfer was not included in Plaintiff’s complaint, the Notice of Intent to Foreclose sent by Servicer in June 2012 listed Owner as the secured party and provided Owner’s telephone number, which put Plaintiff on notice of the transfer over a year before he filed his complaint at the very least.

 

The Court rejected the Defendants’ argument, holding that statute of limitations issues are an affirmative defense and not ordinarily grounds for dismissal.  The Court stated that the Notice of Intent to Foreclose relied on by the Defendants to establish June 2012 as the date Plaintiff was put on notice of the transfer was not integral to Plaintiff’s complaint, and accordingly could not be considered in the context of a motion to dismiss.

 

As to the allegations relating to the assignment of the 2008 Deed of Trust to Servicer, the Defendants argued that the assignment was for administrative convenience to allow Servicer to service the loan.  As you may recall, TILA explicitly states that “[a] servicer of a consumer obligation arising from a consumer credit transaction shall not be treated as the owner of the obligation for purposes of this section on the basis of an assignment of the obligation from the creditor or another assignee to the servicer solely for the administrative convenience of the servicer in servicing the obligation.”  15 U.S.C. § 1641(f)(2).

 

The Court rejected this argument as well, noting that “the Assignment of the Deed of Trust states that it assigns and transfers unto [Servicer] ‘all [lender’s] right, title and interest in and to a certain [2008 Deed of Trust]’.’”  The Court found that “[t]his suggests that [Servicer] was the owner of the Deed of Trust.”

 

Plaintiff also alleged that Servicer violated TILA’s requirements that the name, address, and telephone number of the owner of a loan be provided upon written request.  Plaintiff supposedly requested this information in letters allegedly sent to Servicer in September 2012 and August 2013.  The Defendants argued that Plaintiff was already aware of the owner of the loan prior to sending both letters based on the Notice of Intent to Foreclose Servicer sent Plaintiff in June 2012.  Concerning the alleged August 2013 letter, the Defendants further argued that Plaintiff’s complaint admitted to receiving the foreclosure order to docket, which specifically identified the Owner, at the end of August 2013.

 

The Court rejected both arguments.  The Court noted again that the Notice of Intent to Foreclose could not properly be considered in the context of a motion to dismiss.  It also found that the foreclosure order to docket provided only the name of the Owner, not the Owner’s address and phone number, as required.  Accordingly, the Court held that Plaintiff sufficiently stated a claim for alleged TILA violations.

 

Plaintiff also alleged that Servicer violated RESPA by failing to respond to Plaintiff’s purported qualified written requests.  Among other arguments, Servicer contended that some of Plaintiff’s alleged written requests could not have constituted qualified written requests under RESPA, because they were sent before the applicable response period expired. 

 

The Court rejected Servicer’s position, stating that “[n]othing on the face of RESPA prevents a borrower from inundating his servicer with QWRs, even where the period to respond has not passed,” but also clarifying that “[i]n such a situation, presumably the servicer could satisfy the multiple requests in one response.”  Ultimately, the Court determined that “while some of Plaintiff’s alleged communications do not constitute a QWR, some do and Plaintiff has pled sufficiently that [Servicer] failed to respond and that Plaintiff suffered damages as a result.”

 

Finally, Plaintiff alleged that Owner and Servicer were vicariously liable under the MCDCA for the Substitute Trustees’ actions of purportedly attempting to collect a debt with knowledge that the right to collect did not yet exist.  Specifically, Plaintiff alleged that on August 16, 2013, the Substitute Trustees’ sent Plaintiff a Notice to Occupants stating that a foreclosure sale may occur at any time after forty-five days from the date of the notice, or September 30, 2013. 

 

However, as you may recall, a foreclosure sale of residential property may not occur under Maryland law until at least forty-five days after service of process of the foreclosure order to docket.  Here, Plaintiff alleged that the foreclosure order to docket was not served on Plaintiff until August 28, 2013, meaning that a foreclosure could not be commenced until October 14, 2013.  Thus, according to Plaintiff, the Substitute Trustees were threatening foreclosure any time after September 30, 2013, when they in fact had no such right until October 14, 2013.

 

The Defendants argued, among other things, that their notice complied with Maryland law, pointing to statutory provisions requiring the specific language included in the notice, and outlining the timing with which the notices are to be given.  Notably, the Court – examining Maryland law – held that the notice to occupants should be made simultaneously with when service of the foreclosure order to docket is made, rather than when the foreclosure order to docket is filed.  Therefore, the Court held that Plaintiff’s allegations were sufficient to survive a motion to dismiss.

 

Accordingly, the district court denied the Defendants’ motions to dismiss Plaintiff’s claims under TILA, RESPA, and the MCDCA.

 

 

 

 

Ralph T. Wutscher
McGinnis Wutscher Beiramee LLP
The Loop Center Building
105 W. Madison Street, 18th Floor
Chicago, Illinois 60602
Direct: (312) 551-9320
Fax: (312) 284-4751
Mobile: (312) 493-0874
Email: RWutscher@mwbllp.com

 

Admitted to practice law in Illinois

 

 

          McGinnis Wutscher Beiramee LLP

CALIFORNIA    |  FLORIDA   |   ILLINOIS   |   INDIANA   |   WASHINGTON, D. C.

                                www.mwbllp.com

 

 

NOTICE: We do not send unsolicited emails. If you received this email in error, or if you wish to be removed from our update distribution list, please simply reply to this email and state your intention. Thank you.

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