The answer is a resounding 'Maybe!': An analysis of recent FCC Rulings on the issue of vicarious liability in debt collection
The Telephone Consumer Protection Act (TCPA) provides for statutory damages of up to $1,500 per violation for "willful" behavior. Unlike other statutes aimed at similar conduct, such as the Fair Debt Collection Practices Act, there is no maximum amount of damages that can be imposed under TCPA. The Federal Communications...
These differing rulings by two appellate courts are among the first in what are likely to be many “bumps in the road” for the ACA.
In 1984, the Supreme Court dealt with the question of whether agencies have the power to construe the statutes they are assigned to administer.