Eleventh Circuit Holds That Voicemails Are “Communications” and Clarifies “Meaningful Disclosure” under the FDCPA

Action Item: The Eleventh Circuit held that a first voicemail from a debt collector constitutes a “communication” based on a plain reading of the Fair Debt Collection Practices Act (“FDCPA”). In addition, in a case of first impression, the Eleventh Circuit held that a “meaningful disclosure” is provided under the FDCPA so long as the caller discloses that the call is being made on behalf of a debt collection company and the company’s name.