A claim that a debt collector violated §1692g(a) of the Fair Debt Collection Practices Act (“FDCPA”) must be filed within one-year of the first communication, the Third Circuit recently held in Peterson v. Portfolio Recovery Associates, LLC, Case Nos: 10-2824 & 10-4013, 2011 U.S. App. LEXIS 11453 (3d Cir. June 6, 2011). In this decision, the first by a circuit court on the issue, the court specifically rejects the notion that subsequent communications by a debt collector can constitute separate and discreet violations of §1692g(a). Section §1692g(a) provides that a debt collector must provide a consumer with certain written disclosures…
