The Northern District of Ohio (N.D. Ohio) issued a decision earlier in March that could have significant impact on debt collectors and debt buyers if adopted in other jurisdictions. In Holloway v. JTM Capital Management, LLC, No. 1:18-cv-1794 (N.D. Ohio Mar. 5, 2019), the court denied JTM Capital Management LLC’s (JTM) motion to dismiss and found that reviewing a consumer’s credit report is a third party communication under the Fair Debt Collection Practices Act (FDCPA) and found that passive debt buyers are considered “debt collectors” under the statute.
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