When discussing FCRA, we often concentrate our focus on certain individuals and entities trying to enforce the statute: the CFPB (or BCFP), FTC, class action firms, and individual plaintiffs. Nonetheless, a recent settlement demonstrates the importance of yet another actor—state agencies. In In the Matter of Encore Capital Group, Inc., Midland Funding, LLC, and Midland Credit Management, Inc., a debt buyer learned this lesson while facing a multi-million dollar enforcement action from over 40 states, alleging violations of both FCRA and the Fair Debt Collection Practices Act (the “FDCPA”).
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