If it looks like a debt collector, swims like a debt collector, and quacks like a debt collector, the Sixth Circuit is willing to call it a debt collector. Glazer v. Chase Home Financing, LLC , a January 14, 2013 decision written by Judge Richard Allen Griffin, held that foreclosures fall within the purview of the Fair Debt Collection Practices Act, 15 U.S.C. §1692:
[W]e hold that mortgage foreclosure is debt collection under the Act . . . Lawyers who meet the general definition of a 'debt collector' must comply with the FDCPA when engaged in mortgage foreclosure. And a lawyer can satisfy that definition if his principal business purpose is mortgage foreclosure or if he 'regularly' performs this function.
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