Third Circuit Holds Debt Buyer Plainly Qualified as a “Debt Collector” Under FDCPA


The U.S. Court of Appeals for the Third Circuit held in Tepper v. Amos Fin., LLC, that debt buyers (i.e., entities collecting, on their own behalf, consumer debts they acquired when the debts were in default), can qualify as “debt collectors” under the Fair Debt Collection Practices Act (FDCPA). In doing so, the Third Circuit became the first appellate court to issue a precedential decision addressing the applicability of the U.S. Supreme Court’s 2017 holding in Henson to the “principal purpose” definition of “debt collector” under § 1692a(6) of the FDCPA.