|Received:||10/24/2007 11:36:24 AM|
|Organization:||Brown & Recoup, LC|
|Agency:||Federal Trade Commission|
|Rule:||Debt Collection Workshop|
Comments:This comment addresses state licensing of interstate debt collectors as an obstacle and in restraint of interstate commerce. To illustrate the impact of state licensing of interstate debt collections, I will provide an actual example: A regional debt collection company in the Washington DC area receives an account from one of its clients for a debtor located in Nevada. The debt collection company does not normally collect in Nevada and does not solicit business there. The debt collection company in order to comply with Nevada state law, may not contact the debtor by mail, phone or any other means of communication interstate or otherwise without obtaining regtistration as a foreign agency or license from the State of Nevada. This is overly restrictive and impedes interstate commerce. States should not be allowed to regulate interstate commerce through restrictive licensing laws as Nevada has. The FTC should retain regulatory control over such transactions. States are allowed to regulate occupations within their borders, but allowing them to interfere with interstate commerce is against public policy and the Constitutional provisions for such business. The FTC should exert its efforts to obtain and maintain regulatory control of interstate debt collection.