Galvan v. NCO Portfolio Management, Inc.

Dist. Ct. erred in granting defendant-passive debt buyer’s motion for summary judgment in action alleging that defendant’s activities in purchasing large quantities of Illinois consumers’ defaulted debt and referring collection of said debt to its related corporate entity qualified defendant as “collection agency” under Illinois Collection Agency Act (ICAA) that in turn subjected defendant to registration requirements under ICAA. Illinois Supreme Court, in LVNV Funding, LLC v. Trice, 32 N.E. 3d 553, concluded that passive debt buyer using third-party to collect on said debt qualified as collection agency, and thus Ct. of Appeals reversed contrary holding by Dist. Ct. and remanded case for further consideration of other issues raised by defendant.