FDCPA vs. Bankruptcy Remedies: The 2nd Circuit Reversal in Garfield v. Ocwen Loan Servicing

In a case that is likely to have a broad effect on the collection activities of debt collectors in New York, the Second Circuit recently held that the Bankruptcy Code does not prevent use of the Fair Debt Collection Practices Act (FDCPA) in a claim regarding a debt that was discharged in bankruptcy proceeding. In…