Christopher Lipsett, Esquire
Dear Mr. Lipsett:
This is in response to your letter of May 14, 1990, to Jean Noonan, in which you outline certain "pre-collection" activities of your client, G.C. Services Limited Partnership. You note your belief that these activities would be permissible under previous opinions issued by the staff as well as the Staff Commentary on the Act. You ask whether or not we have changed our views on Section 812 of the Act as expressed in the Commentary and, if so, whether the G.C. Services "pre-collection" activities would violate that Section.
The staff views set out in the Commentary remain the same. Based on the facts outlined in your letter, we do not believe that G.C. Services pre-collection activities would violate the requirements of Section 812 of the Fair Debt Collection Practices Act.
The views expressed in this letter represent informal staff opinion and as such are not binding upon the Commission. They do reflect our current enforcement position, however.
Roger J. Fitzpatrick