[{"data":1,"prerenderedAt":-1},["ShallowReactive",2],{"detail-sidebar-cat-1-en-105":3,"doc-seo-280439-105":53,"doc-detail-280439-en":126},{"code":4,"msg":5,"data":6},0,"success",[7,14,19,24,29,34,39,44,49],{"id":8,"doc_module":9,"doc_module_name":10,"category_name":11,"show_sort_weight":12,"slug":13},11,1,"Template","Presentations",90,"presentations",{"id":15,"doc_module":9,"doc_module_name":10,"category_name":16,"show_sort_weight":17,"slug":18},12,"Resumes",80,"resumes",{"id":20,"doc_module":9,"doc_module_name":10,"category_name":21,"show_sort_weight":22,"slug":23},14,"Invoices",70,"invoices",{"id":25,"doc_module":9,"doc_module_name":10,"category_name":26,"show_sort_weight":27,"slug":28},15,"Posters",60,"posters",{"id":30,"doc_module":9,"doc_module_name":10,"category_name":31,"show_sort_weight":32,"slug":33},16,"Social Media",50,"social-media",{"id":35,"doc_module":9,"doc_module_name":10,"category_name":36,"show_sort_weight":37,"slug":38},17,"Forms",40,"forms",{"id":40,"doc_module":9,"doc_module_name":10,"category_name":41,"show_sort_weight":42,"slug":43},18,"Letters",30,"letters",{"id":45,"doc_module":9,"doc_module_name":10,"category_name":46,"show_sort_weight":47,"slug":48},21,"Paper Templates",5,"papers-templates",{"id":50,"doc_module":9,"doc_module_name":10,"category_name":51,"show_sort_weight":4,"slug":52},158,"General","general-158",{"code":4,"msg":54,"data":55},"ok",{"site_id":56,"language":57,"slug":58,"title":59,"keywords":60,"description":61,"schema_data":62,"social_meta":119,"head_meta":121,"extra_data":123,"updated_unix":125},105,"en","recent-developments-debt-collection-and-bankruptcy","Recent Developments - Debt Collection and Bankruptcy","","Recent developments in debt collection and bankruptcy address two key legal issues involving consumer protection and income calculation. In the debt collection matter, a court granted partial summary judgment where a debt collector continued contacting the debtor after receiving a cease-and-desist notification, holding that the FDCPA permits one communication only after such notice. In the bankruptcy matter, a court reversed and remanded a Chapter 13 plan because projected disposable income should account for known or virtually certain income changes, such as a newly secured job, instead of relying solely on the six-month retroactive Form B22C period.",{"@graph":63,"@context":118},[64,80,101],{"@type":65,"itemListElement":66},"BreadcrumbList",[67,71,74,77],{"item":68,"name":69,"@type":70,"position":9},"https://docshare.wps.com","Home","ListItem",{"item":72,"name":10,"@type":70,"position":73},"https://docshare.wps.com/template/",2,{"item":75,"name":51,"@type":70,"position":76},"https://docshare.wps.com/template/general/",3,{"item":78,"name":59,"@type":70,"position":79},"https://docshare.wps.com/template/recent-developments-debt-collection-and-bankruptcy/280439/",4,{"url":78,"name":59,"@type":81,"image":82,"author":87,"headline":59,"publisher":90,"fileFormat":93,"inLanguage":57,"description":61,"dateModified":94,"datePublished":95,"encodingFormat":93,"isAccessibleForFree":96,"interactionStatistic":97},"DigitalDocument",{"url":83,"@type":84,"width":85,"height":86},"https://docshare.wps.com/thumbnails/recent-developments-debt-collection-and-bankruptcy/280439.png","ImageObject",442,249,{"name":88,"@type":89},"Violet","Person",{"url":68,"name":91,"@type":92},"DocShare","Organization","application/pdf","2026-09-23","2026-09-16",true,{"@type":98,"interactionType":99,"userInteractionCount":79},"InteractionCounter",{"@type":100},"ViewAction",{"@type":102,"mainEntity":103},"FAQPage",[104,110,114],{"name":105,"@type":106,"acceptedAnswer":107},"Under the FDCPA, how many times may a debt collector contact a consumer after receiving a cease-and-desist letter?","Question",{"text":108,"@type":109},"The FDCPA allows the debt collector to contact the consumer one time after receiving the cease-and-desist notice.","Answer",{"name":111,"@type":106,"acceptedAnswer":112},"Does a cease-and-desist letter need to include the exact phrase “cease further communication” to be effective?",{"text":113,"@type":109},"No. The court held that even without the precise words, the letter’s context made it clear the consumer did not want to be contacted regarding the same debt.",{"name":115,"@type":106,"acceptedAnswer":116},"In Chapter 13 bankruptcy, should projected disposable income be based only on Form B22C’s six-month retroactive calculation?",{"text":117,"@type":109},"No. When circumstances change, a court may account for known or virtually certain changes at confirmation, including a newly secured job, rather than relying solely on the retroactive Form B22C period.","https://schema.org",{"og:url":78,"og:type":120,"og:title":59,"og:site_name":91,"og:description":61},"article",{"robots":122,"canonical":78},"index,follow",{"doc_id":124,"site_id":56},280439,1789548235,{"code":4,"msg":5,"data":127},{"doc_id":124,"user_id":128,"nickname":88,"user_avatar":129,"doc_module":9,"category_id":50,"category_name":51,"doc_title":59,"doc_description":61,"doc_content":130,"file_id":131,"file_url":132,"file_type":133,"file_size":134,"view_count":79,"is_deleted":4,"is_public":9,"is_downloadable":9,"audit_status":9,"page_count":79,"language":135,"language_code":57,"site_id":56,"html_lang":57,"table_of_contents":136,"faqs":137,"seo_title":138,"seo_description":61,"update_tm":125,"read_time":73},4398048950312,"https://ap-avatar.wpscdn.com/avatar/400002538284de19e3c?_k=1778320343897328908","RECENT DEVELOPMENTS  \nDEBT COLLECTION AND BANKRUPTCY  \nDEBT COLLECTOR VIOLATED FDCPA LAW WHEN IT CONTINUED TO CONTACT DEBTOR  \nJeff Bishop v. I.C. System, Inc.,   F.Supp.2d   (M.D. Fla. 2010) .  \nFACTS: Plaintiffs Jeff and Heidi Bishop filed for a motion for summary judgment against Defendant I.C. System for violation of the Fair Debt Collection Practices Act (“FDCPA”) . The Defendant claimed that the letter provided by the Plaintiffs did not trigger § 1692c(c) of the Act, which prohibits a debt collector from contacting a consumer after being notified in writing by the consumer that communication must stop. The notification provided by Plaintiffs stated that “Any further correspondence from your organization or any other collection agency will be discarded or returned to you unopened.” The Defendant, however, continued to contact the Plaintiffs after receiving the letter. The Plaintiffs sued the Defendant in the 13th Judicial Circuit of Florida. The Complaint was removed to federal court. In Count One of their complaint, the Plaintiffs raised four claims, one of which included violation of §1692c(c) of the FDCPA. The Plaintiffs moved for partial summary judgment on this claim.  \nHOLDING: Granted.  \nREASONING: The court concluded there was no genuine issue of material fact on the §1692c(c) claim. In making its decision, the court considered undisputed material facts and the sufficiency of the Plaintiffs’ letter to the Defendant debtor.  \nIt was undisputed that the Plaintiffs were consumers,  \nThe FDCPA allows the debt collector to contact the consumer onetime after receiving the consumer’s cease-anddesist letter.  \nthey allegedly owed a debt, and the Defendant was a debt collector. It was also undisputed that the Plaintiffs sent a letter to the Defendant regarding this issue, and the Defendant received the letter. Further, it was undisputed that the De-  \nfendant contacted the Plaintiff by mail and by phone on more than one occasion after receiving this letter. The FDCPA allows the debt collector to contact the consumer one time after receiving the consumer’s cease-and-desist letter. In the instant case, the Defendant debt collector contacted the Plaintiffs more than once after receiving the letter. The debt collector can contact the consumer about other debts or future debts after receiving a ceaseand desist letter, but they cannot contact the consumer regarding the same debt addressed in the letter. It was undisputed that the contact between Plaintiff and Defendant, after the letter was received by the debt collector, was in regards to the debt addressed in the letter.  \nThe Defendant argued that the letter provided by the Plaintiffs did not sufficiently notify the debt collector to cease further communication according the statute, so they were free to continue communicating regarding the debt. The court determined that even though the precise words,“cease further communication” were not used, the letter still expressed the same mes-  \nsage, and consumers did not have to use specific language to tell the debt collector to cease communication. The letter indicated that the Plaintiff did not want to be contacted by the Defendant anymore. The court concluded that even though the letter did not literally ask the Defendant to cease communication, its context made it clear that the Plaintiff did not want to be disturbed by the defendant anymore. The court agreed to partial summary judgment on this claim because it determined that any jury would conclude that the letter demanded the Defendant stop contacting the Plaintiffs, and no reasonable disagreement existed about the inferences to be drawn from the Plaintiffs’ letter.  \nIN BANKRUPTCY, DEBTOR’S INCOME SHOULD BE BASED ON NEW JOB  \nDavid Andrew Darrohn v. Henry E. Hildebrand, III,   F.3d   (6th Cir. 2010) .  \nFACTS: David and Marguerite Darrohn filed a voluntary petition for bankruptcy under Chapter 13 of the Bankruptcy Code. They listed their disposable monthly income on Form B","cbCaifk7plbxBR8M","https://ap.wps.com/l/cbCaifk7plbxBR8M","pdf",249839,"English","# Recent Developments\n# Debt Collection and Bankruptcy","[{\"question\":\"Under the FDCPA, how many times may a debt collector contact a consumer after receiving a cease-and-desist letter?\",\"answer\":\"The FDCPA allows the debt collector to contact the consumer one time after receiving the cease-and-desist notice.\"},{\"question\":\"Does a cease-and-desist letter need to include the exact phrase “cease further communication” to be effective?\",\"answer\":\"No. The court held that even without the precise words, the letter’s context made it clear the consumer did not want to be contacted regarding the same debt.\"},{\"question\":\"In Chapter 13 bankruptcy, should projected disposable income be based only on Form B22C’s six-month retroactive calculation?\",\"answer\":\"No. When circumstances change, a court may account for known or virtually certain changes at confirmation, including a newly secured job, rather than relying solely on the retroactive Form B22C period.\"}]","Recent Developments - Debt Collection and Bankruptcy | PDF"]