Consumer complaint received 2025-11-03 00:00:00
Product: Debt collection — Credit card debt
Issue: Took or threatened to take negative or legal action — Sued you without properly notifying you of lawsuit
Company: Moss Law Firm, P.C.
State: TX

Complaint narrative:
This complaint serves as a comprehensive escalation and reply to Moss Law Firm, P.C.s XX/XX/XXXX submission to the Consumer Financial Protection Bureau ( CFPB ). The firms filings contain factual inaccuracies and misrepresentations of federal law. This response clarifies the correct legal standards under the Fair Debt Collection Practices Act ( FDCPA ) and Regulation F, highlights the firms deflection tactics, and documents its misleading use of the CFPBs safeharbor concept. 
This complaint requests that the Consumer Financial Protection Bureau formally recognize and act on a pattern of unlawful debtcollection conduct by Moss Law Firm, P.C., representing XXXXXXXX XXXX XXXX XXXX. The firms behavior mirrors other law firms the CFPB has already taken enforcement action against for similar violations, such as XXXXXXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX  XXXX XXXX. ( XXXX ). Moss Law Firms continued reliance on outdated validation standards and misrepresentation of federal requirements demonstrates the same type of deceptive practice that has drawn prior CFPB enforcement.

1. Misrepresentation of Federal Law and the CFPBs Position Moss Law Firms XX/XX/XXXX response misstates federal law by claiming that minimal validation such as providing only account statements satisfies the FDCPA and that the CFPB agrees with this interpretation. This is false. The firm continues to rely on obsolete case law and misleading references to CFPB policy to justify incomplete validation. While older cases such as XXXXXXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX  and related Texas decisions addressed what might constitute verification under 15 U.S.C. 1692g ( b ), those rulings predated the CFPBs XXXX Debt Collection Rule. Regulation F did not wholly replace judicial interpretations of verification, but it standardized the content required in every initial validation notice and established a safe harbor only when collectors use the Model Validation Notice or a substantially similar format. Simply invoking safe harbor while failing to use the CFPBs model notice or to include all required elements is misleading. Likewise, continuing collection activity or filing suit before mailing verification in response to a written dispute violates 1692g ( b ). On XX/XX/XXXX, the CFPBs Debt Collection Rule ( Regulation F, 12 C.F.R. 1006.34 ) took effect, replacing inconsistent judicial interpretations of 15 U.S.C. 1692g ( b ). Regulation F standardizes validation and requires the following elements in every debtcollector notice : Itemization of the debt ( principal, interest, fees, payments, and credits ) tied to an itemization date ( 1006.34 ( c ) ( 2 ) ( viii ) ).

Identification of both the current and original creditor ( 1006.34 ( c ) ( 2 ) ( iii ) ( iv ) ).

Consumerrights disclosures explaining dispute and verification options ( 1006.34 ( c ) ( 3 ) ).

A tearoff response form or substantially similar feature ( 1006.34 ( d ) ( 3 ) ). 
Use of the standardized Model Validation Notice ( Appendix B ) for safeharbor compliance. 
As confirmed in XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX, the CFPB adopted these requirements to provide clarity, standardization, and prevent consumer confusion caused by inconsistent and incomplete validation notices. By relying on obsolete precedent and implying CFPB endorsement, Moss Law Firm engages in deceptive conduct prohibited by 15 U.S.C. 1692e ( 10 ).

2. Deflection and Mischaracterization The firm repeatedly deflects from the central issue failure to provide proper validation by mischaracterizing the complaint as being about XXXX XXXX name. The name issue arose only because the firm filed under an outdated name despite having received certified correspondence showing her current legal name. This deflection serves to divert attention from the firms noncompliance with Regulation F validation requirements. 
3. Misuse of SafeHarbor Language The firm falsely claims that its response complies with the CFPBs safeharbor form, suggesting that the Bureau supports its interpretation. However, the Model Validation Notice referenced in Regulation F is designed to standardize disclosures not to excuse incomplete validation. Moss Law Firms reference to the safeharbor form is deceptive and misleading, constituting a violation of 15 U.S.C. 1692e ( 10 ).

4. Pattern of Misleading Conduct Moss Law Firms behavior mirrors patterns seen in other consumer complaints, where the firm repeatedly relies on outdated case law and dismisses Regulation F obligations. This conduct reflects systemic disregard for the CFPBs modernization of the debtcollection validation process and warrants formal review by the Bureaus enforcement division. 
Supporting documentation, including certified mailing receipts are available to the CFPB upon request.

Company response to consumer: Closed with explanation