Collector Using a Name to Imply Credit Rating Damage

[David A. Szwak]

The Ninth Circuit held that use of the name Credit Protection Association did not imply to the least sophisticated consumer that if the debt was not paid CPA would damage the consumer's credit by reporting to a credit reporting agency. Dunlap v. Credit Protection Association, L.P., 419 F.3d 1011 (9th Cir. 2005).