UNITED STATES OF AMERICA
September 13, 1996
Anne P. Fortney, Esq.
Dear Ms. Fortney:
This is in reply to your letter of July 22, 1996, concerning whether the servicer of a "private label" credit card or the merchant at whose stores the credit card is accepted is a "debt collector" under the Fair Debt Collection Practices Act (FDCPA). I incorporate by reference the facts set forth in your letter in this reply.
My opinion remains unchanged from that given to you in our recent telephone conversation. Based on the information in your letter, I believe that:
Please be advised that this is the opinion of the Commission staff and is not binding upon the Commission itself.
John F. Lefevre