9th Cir. Says “Initial Communication” under the FDCPA Applies to Each Successive Debt Collector on a Debt — Each Successor Debt Collector Must Demonstrate Compliance with the FDCPA

In Hernandez v. Williams, Zinman & Parham PC, No. 14-15672 (9th Cir. 2016), the Court of Appeals for the Ninth Circuit held that the FDCPA unambiguously requires any debt collector – first or subsequent – to send a section 1692g(a) validation notice within five days of its first communication with a consumer in connection with the collection of any debt.   A copy of the decision is here.