Debt Collection Lawsuit Documentation Register

PROBLEM: On 11 January 2023 the CFPB announced a settlement in its lawsuit against debt-collection law firm Forster & Garbus, LLP, sued in 2019. The CFPB alleged that from 2014 through 2016 fewer than a dozen attorneys at the firm filed more than 99,000 debt-collection lawsuits while having documents to support only a fraction of those debts, and falsely represented that attorneys were meaningfully involved in preparing and filing the lawsuits, violating the Fair Debt Collection Practices Act and the Consumer Financial Protection Act. The proposed order requires specific supporting documents and attorney review before any new suit, dismissal of non-compliant pending suits, and a $100,000 penalty.

SOLUTION: An IBM Cloud Ideas compliance register that records, per debt-collection lawsuit, the supporting documents held, the attorney who reviewed them and when, the debt amount and its source, and the filing date, blocking a filing from being marked ready until the document set and attorney-review certification are both recorded.

EVIDENCE BASIS: DOCUMENTED — CFPB, 11 Jan 2023: settlement with Forster & Garbus, LLP; >99,000 debt-collection lawsuits filed 2014–2016 by fewer than a dozen attorneys, with documents supporting only a fraction; $100,000 penalty; document-support and attorney-review requirements.