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Second Circuit Holds That FDCPA Does Not Apply to Proof of Claim in Bankruptcy

The Second Circuit has held that an allegedly inflated proof of claim cannot form the basis for a claim under the Fair Debt Collection Practices Act. Simmons v. Roundup Funding , No. 09-4984 (2 nd Cir. 10/5/10). The opinion can be found here . In Simmons , Roundup Funding filed a proof of claim...