Question:
Maguire, a credit card holder at Bradlees Department Store, fell behind in her payments. She received a series of dunning letters from Citicorp, which managed Bradlees’ accounts, demanding that she pay the overdue amount. Later Maguire received a letter from “Debtor Assistance,” which said that “your Bradlees account has recently been charged off.” Debtor Assistance is a unit of Citicorp, but was not identified as such in the letter, beyond the phrase “a unit of CRS.” The back of each Bradlees’ account statement includes a notice that Citicorp Retail Services was the creditor that handled Bradlees’ accounts. In general, creditors are not subject to the requirements of the Fair Debt Collections Practices Act, but Maguire sued claiming the Debtor Assistance letter violated the FDCPA. Is she correct? Explain.