I don't know, but am guessing, that the attorney claims his primary business is the title company. So if he's hired to collect debts for an HOA, does he still have to abide by FDCPA?
The answer to this is a little unclear at the moment. There is actually a federal class action case pending in the Western District of Virginia concerning this very issue. The answer depends very heavily depending on how notices are sent and what the engagement letter states.
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