On Thursday, the Seventh Circuit Court of Appeals (7th Cir.) published its long-awaited opinion in the matter of Lavallee v. Med-1 Solutions, LLC, 17-3244 (7th Cir. Aug. 8, 2019). Critically, the 7th Cir. found that an email containing no disclosures or information about a debt, but rather a hyperlink where such information can be securely accessed, is not a communication under the Fair Debt Collection Practices Act (FDCPA). An interesting question arises: what does this decision mean for text messaging and call frequency limits as outlined in the Consumer Financial Protection Bureau's (CFPB) Notice of Proposed Rulemaking (NRPM) for debt collection?
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