Yergovich v. Small Cmty. Specialists LLC

Although one of an HOA manager’s duties was to contact residents about unpaid dues, debt collection was only incidental to the managing company’s fiduciary obligations to the HOA. Thus, the company wasn’t a “debt collector” and is entitled to summary judgment as to claims asserted under the Fair Debt Collection Practices Act.

Yergovich v. Small Cmty. Specialists LLC, No. 1:17cv685, Sept. 11, 2018. EDVA at Alexandria (Ellis).



Categories: Opinions, U.S. District Court - Eastern District of Virginia

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