Submission Number: 00077
Received: 11/22/2010 12:52:37 PM
Commenter: Lily Schaefer
Agency: Federal Trade Commission
Initiative: Statement of Policy Regarding Communications in Connection with Collection of a Decedent’s Debt; Project No. P104806
Attachments: No Attachments
Debt collection practices are already draconian enough. Any proposed FTC regulation on contacting family members of deceased persons should be unequivocably stringent.
I have been practicing law in Indiana for 32 years, representing creditors. Being very familiar with unscrupulous debt collectors, I urge the FTC not to expand the rights of debt collectors in this area, or enact rules which have the unintended consequence of allowing debt collectors to "shame" family members and widows and widowers into paying debts for which they bear no legal responsibility.
Any new regulations should have plainly worded prohibited practices, with substantial penalties for violation, giving surviving family members standing to sue those who violate the law.
PLEASE do not allow the industry to write your regulations, as has been the case for the entire 8 years of the previous administration.