The United States Court of Appeals for the Ninth Circuit recently affirmed a district court’s holding that the trustee of a California deed of trust is not a “debt collector” under the Fair Debt Collection Practices Act (“FDCPA”) because the trustee only was enforcing a security interest. See Ho. v. Recontrust Company, N.A., 840 F.3d 618 (9th Cir. 2016). In the case, the plaintiff purchased a house using a loan that was secured by a deed of trust. After the plaintiff began missing loan payments, the defendant trustee initiated a non-judicial foreclosure.