Brannan executed a promissory note for a loan under the
former Guaranteed Student Loan (GSL) program. USA Funds, a private guarantee agency under
contract with the U.S. Department of Education, guaranteed the loan. The Department
insured USA Funds. After the lender's assignee declared Brannan in default and filed a
default claim with USA Funds, the Agency paid the loan and began collection efforts.
Brannan sued USA Funds, alleging violation of the Fair Debt
Collection Practices Act by (1) threatening to cause her to lose her job, (2)
communicating with third parties about the debt, and (3) refusing to communicate about the
debt through her attorney. The trial court granted defendant summary judgment, holding
that it was exempt from the FDCPA under §1692 (a)(6)(c) which exempts "any officer
employee of the United States or any state to the extent that the collecting or attempting
to collect any debt is in the performance of his official duties"
The Ninth Circuit reversed. It rejected USA's argument that
Congress did not intend for the FDCPA to apply to government student loan guarantee
agencies. The ad proscribes abusive collection practices, by "any person who
regularly collects or attempts to collect" debts. The Circuit Court noted that FDCPA
does not provide an exemption for guaranty agencies that acquire a student loan after
default in order to pursue its collection. Moreover, the court said, Department of
Education regulations explicitly provide that GSL third party collectors and their
collection activities-are subject to the Fair Debt Collection Practices Act.
The Court said that the exemption referred to in the FDCPA
applies "only to individual government officials or employees who collect debts as
part of their official duties". In this case, the agency is a private, not for profit
organization with a government contract. It is not a government agency and, thus is not
exempt.