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Bona fide error defense

Bona fide error defense — The bona fide error defense relieves a debt collector of FDCPA liability if it proves by a preponderance of the evidence that the violation was unintentional and resulted from a bona fide error notwithstanding the maintenance of procedures reasonably adapted to avoid such error.

The defense lives at 15 U.S.C. § 1692k(c) and has three independent elements — unintentional, bona fide, and procedures reasonably adapted — all of which the collector bears the burden of proving. In Jerman v. Carlisle, McNellie, Rini, Kramer & Ulrich LPA, decided April 21, 2010, the Supreme Court held the defense does not reach a violation resulting from a debt collector's mistaken interpretation of the FDCPA's legal requirements. That holding is why the defense is, in practice, a clerical-error and systems-failure defense: it protects the firm whose letter vendor merged the wrong balance, not the firm whose counsel read § 1692g wrong.

Primary sources

  1. 15 U.S.C. § 1692k(c); Jerman v. Carlisle, McNellie, Rini, Kramer & Ulrich LPA (U.S. Apr. 21, 2010)

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This is an informational reference, not legal advice, and using it creates no attorney-client relationship. Limitations periods turn on facts this page cannot know — which state's law governs, the contract type, when the claim accrued, and whether anything tolled or revived it. Confirm against the primary source and your own counsel before acting.