Bernal v. NRA Group, LLC

Dist. Ct. did not err in finding that defendant debt-collector’s $43.28 cost to mail single collection letter counted as “collection cost” under contract between parties for purposes of section 1692(f) of Fair Debt Collection Practices Act, even though plaintiff-debtor argued that said cost violated section 1692(f) because it was not “expressly authorized by the agreement creating the debt.” Contract at issue allowed for creditor to collect “any cost”, and most reasonable reading of said term is to include fees paid in attempting to collect on instant debt. Fact that instant cost had not been incurred at time demand was made did not require different result, since creditor would be responsible for $43.28 cost if debtor paid on debt.