Consumer complaint received 2025-12-28 00:00:00
Product: Debt collection — Other debt
Issue: Attempts to collect debt not owed — Debt is not yours
Company: Paramount GR Holdings, LLC
State: LA

Complaint narrative:
On XX/XX/XXXX, I sent GoodLeap a formal demand for immediate cessation of all collection attempts. That communication cited the widows emotional distress, revoked any prior or implied contact consent under the TCPA and FDCPA, and warned that failure to comply would compel me to pursue legal remedies.

Despite receiving and acknowledging that letter, GoodLeap failed to cease communications or resolve the matter. Their reply acknowledged the widows distress but improperly requested internal estate records which I clarified were neither legally required nor voluntarily provided.

Additionally, a lien search conducted through the Clerk of Court in XXXX XXXX confirms that no UCC-1 Financing Statement or other lien was ever recorded by GoodLeap against any personal property prior to XXXX XXXX death or closure of estate. 
On XX/XX/XXXX, GoodLeap contacted me ( XXXX XXXX ) directly and demanded that I, a non-borrower, pay a past due amount of {$110.00}. This was done despite their prior knowledge of the borrowers death, succession closure, and my repeated statements that I held no personal liability. I immediately responded, reaffirming that the debt was not mine and that no enforceable claim remained. I warned that further demands would trigger legal escalation.

GoodLeap replied to acknowledge receipt, promised to halt collection efforts, yet failed to resolve the account and continued to leave it open. This incident constitutes a direct and knowing attempt to collect a debt from a non-liable party, in violation of the Fair Debt Collection Practices Act.

I am writing in my capacity as : 1. Personal Representative of the Estate of XXXX XXXX XXXX 2. Attorney-in-Fact for XXXX XXXX, surviving spouse and current resident 3. Lawful possessor and representative of the real property formerly owned by the borrower XXXX XXXX XXXX, the sole borrower on the referenced account, passed away on XX/XX/XXXX. GoodLeap was notified of his death on XX/XX/XXXX. A probate proceeding was subsequently opened in Louisiana. GoodLeap did not file a creditor claim during the probate window. The Judgment of Possession was signed and recorded in XX/XX/XXXX, closing succession. 
No UCC-1 Financing Statement, mortgage, or other lien was recorded by GoodLeap in Louisiana prior to the death of XXXX XXXX . Accordingly, GoodLeap holds no perfected security interest, and no longer holds any valid estate-based claim for debt recovery.

Despite multiple written notices and legal notifications, GoodLeap has continued collection activity and made physical contact with the property, in violation of state and federal law.

GoodLeap received timely notice of the borrowers death but failed to assert any claim through Louisiana 's succession process. No UCC-1 Financing Statement was ever filed prior to the borrowers death. We were under no legal obligation to provide internal estate documentation to a private lender, and GoodLeap had full opportunity to pursue any rights it believed it had but failed to do so.

The following are a matter of public record : - XXXX XXXX, the sole borrower, is deceased - Succession has been completed - No claim was filed by GoodLeap during the succession proceedings - No UCC-1 Financing Statement was ever filed Accordingly, there appears to be no continuing enforceable claim against the deceased, XXXX XXXX , the estate, or any personal property including the generator.

This letter also confirms that, in the absence of any valid claim filed during succession, all payments on the loan were permanently discontinued effective XX/XX/XXXX. GoodLeap has not presented any enforceable basis for further performance, and the matter was deemed legally closed as of that date.

I. CEASE COMMUNICATION FDCPA 15 U.S.C. 1692c ( c ) This statute requires debt collectors to cease communication upon written notice from the consumer ( or their legal representative ) stating that they refuse to pay or wish no further contact. After such notice is received, the debt collector may only communicate to confirm termination of efforts, notify of legal action, or provide court-ordered information.

In this case : - GoodLeap was notified in writing of XXXX XXXX death on XX/XX/XXXX - A formal cease-communication request was sent in XX/XX/XXXX - Despite this, GoodLeap continued XXXX mail monthly billing statements addressed to the deceased borrower and physically posted notices at the residence in XX/XX/XXXX None of the statutory exceptions apply. XXXX continued contact is a direct and ongoing violation of 1692c ( c ).

II. THIRD-PARTY DISCLOSURE FDCPA 15 U.S.C. 1692c ( b ) This section prohibits communication with third parties about a consumers debt unless expressly permitted by the consumer or required by law. Continued communication with a deceased borrower at a home occupied only by a non-debtor violates this section.

Mailing debt-related materials to a deceased borrower at an address now solely occupied by a non-debtor ( the widow ) creates constructive third-party disclosure.

Facts : - The borrower is deceased - The current resident his widow is not a co-signer, guarantor, or successor in interest - GoodLeap has continued sending debt-related notices to the property These communications are reasonably interpreted as disclosures of debt to a third party. This behavior violates 1692c ( b ).

III. HARASSMENT AND ABUSE FDCPA 15 U.S.C. 1692d This section prohibits
any conduct where the natural consequence is to harass, oppress, or abuse the consumer or any person in connection with debt collection.

Facts : - GoodLeap has continued to address letters to a deceased person - These letters are received by the surviving widow, age XXXX, who panics upon receiving them - One or more visits were made to the home, including physically leaving materials after a cessation of communication was demanded by parties legally empowered to make such a demand This repeated conduct causes distress and confusion to someone who is not legally responsible for the debt and violates 1692d. 

IV. UNFAIR OR UNCONSCIONABLE COLLECTION FDCPA 15 U.S.C. 1692f This provision prohibits unfair or unconscionable means of debt collection, including efforts to collect non-existent or legally barred debts.

Attempting to collect a debt that : Is unsecured Was never claimed in probate Is not owed by the current occupant is both deceptive and unlawful.

Facts : - GoodLeap did not file a creditor claim during succession under Louisiana law - No enforceable lien or collateral interest was perfected - The estate is closed - There is no successor debtor, and no court-ordered liability for the surviving spouse Attempting to collect under these circumstances particularly through indirect pressure on the surviving resident violates 1692f.

V. NONCOMPLIANCE WITH CFPB REGULATION F 12 C.F.R. 1006.6 et seq.

Regulation F requires debt collectors to implement procedures that prevent contact with consumers who are deceased and to respect cease communication notices.

Facts : - GoodLeap has continued collection activity more than 10 months after notice of the borrowers death - The legal representative has issued multiple cease-contact notices- GoodLeap has shown intent to continue contact despite
being provided written probate closure These acts show willful noncompliance with CFPB regulations requiring debt collectors to have procedures to avoid contacting deceased persons or unauthorized third parties.

VI. CIVIL LIABILITY FOR DAMAGES FDCPA 15 U.S.C. 1692k For each statutory violation described above, GoodLeap is subject to : - Actual damages, including for emotional distress - Statutory damages, up to {$1000.00} per proceeding- Attorneys fees and costs, if the matter is escalated The record of correspondence, legal notifications, and continued contact after probate
provides clear evidence of liability under 1692k.

VII. TRESPASS UNDER LOUISIANA LAW La. Civ. Code arts. 3412, 3421, and 2315 ; La. R.S. 14:63.3 - Article 3412 defines possession as the enjoyment of a thing - Article 3421 protects a possessor against disturbances - R.S. 14:63.3 makes entry onto immovable property without legal right or consent a criminal trespass GoodLeap dispatched an agent to the home to place written materials on the property, despite receiving written revocation of all prior license or authority to enter.

Any additional intrusion will be unlawful.

VIII. EMOTIONAL DISTRESS AND PRIVACY INVASION LOUISIANA TORT LAW La. Civ. Code art. 2315 ; XXXX XXXX XXXX, XXXX XXXX XXXX ( La. XXXX ) Article XXXX provides that any act which causes damage to another obligates the actor to repair it. Louisiana recognizes intentional infliction of emotional distress as actionable where conduct is outrageous and causes severe emotional harm.

GoodLeaps continued contact in writing and in person after notice of death, probate closure, and multiple written objections, is intentional conduct causing emotional injury to a vulnerable, elderly person. It may also constitute an invasion of privacy, by repeatedly disrupting her peaceful occupation of the home with legal threats addressed to her deceased spouse.

VIII. CFPB COMPLAINT AND GOODLEAPS ADMISSIONS On XX/XX/XXXX, a formal complaint with the CFPB was filed. In response, GoodLeap admitted : There is currently no active party assuming responsibility for the loan.

They would file a UCC-1 Fixture Filing on XX/XX/XXXX, post-succession On XX/XX/XXXX, GoodLeap wrote that collection activity will continue until payment arrangements are made, despite having no legal basis to do so.

All of which violates the following : 15 U.S.C. 1692f Unfair or Unconscionable Means to Collect a Debt This section prohibits any unfair or unconscionable means of debt collection.

GoodLeap has admitted that there is currently no active party assuming responsibility for the loan. Despite this, they continued collection efforts and stated in writing that collection activity will continue until payment arrangements
are made.

These actions are unfair, legally baseless, and constitute a direct violation of 1692f.

________________________________________ 15 U.S.C. 1692e False or Misleading Representations This provision prohibits debt collectors from making false, deceptive, or misleading representations, including misstating the legal status of a debt.

GoodLeaps claim that collection will continue after admitting there is no liable party and after failing to file a claim in probate constitutes a false representation of enforceability. This is a clear violation of 1692e.

________________________________________ 12 C.F.R. 1006.6 Regulation F ( CFPB ) This CFPB regulation requires debt collectors to have procedures in place to avoid contacting deceased consumers or unauthorized third parties, and mandates cessation of communication when no legal representative or successor exists.

GoodLeap acknowledged that no party had assumed responsibility for the debt, yet continued to direct collection efforts to a third party ( you ), including written communications and personal outreach.

This conduct violates Regulation F and demonstrates a lack of compliant internal procedures.

________________________________________ Louisiana Civil Code art. 2315 Civil Liability for Damages Under Louisiana law, any act that causes damage to another obliges the actor to repair it.

By continuing unlawful collection efforts after legal notice, and despite acknowledgment of their inapplicability, GoodLeap has caused repeated emotional harm to the surviving widow.

This behavior gives rise to civil liability under Article 2315, particularly as the conduct was knowing and avoidable.

This continued conduct is unlawful.

IX. EMOTIONAL DISTRESS & PRIVACY INVASION LOUISIANA La. Civ. Code art. 2315 ; White v. Monsanto, 585 So.2d 1205 ( La. 1991 ) The pattern of contact and disregard for the legal process has caused severe distress to the elderly widow.

These repeated emotional harms are unlawful.

IX. DEMANDS You are hereby directed to : 1. Immediately cease all communication and contact regarding this account 2. Confirm in writing that the account is closed for all collection purposes 3. Permanently refrain from any physical presence or delivery at the residence 4. If GoodLeap no longer owns or services this loan, provide the name and address of any current holder within 10 business days

Company response to consumer: Closed with explanation