Whether the FDCPA requires third party debt collectors to conduct an independent preemptive investigation to review for all potential defects or challenges to the debt before mailing the validation notice, and whether the bona fide error defense is limited to internal policies or excludes pre-placement procedures with the original creditor, and whether a medical debt incurred during employment is considered a consumer debt

The questions presented are: 1. Whether the FDCPA requires third party debt collectors to conduct an independent preemptive investigation to review for all potential defects or challenges to the debt, including its legal status, before mailing the 1692g notice of validation, irrespective of any reasonable reliance upon the creditor’s representations? 2. Whether the FDCPA’s bona fide error defense is limited only to the third party debt collector’s own internal policies and procedures, and excludes any development of pre -placement procedures with the original creditor to avoid violations? 3. Whether a medical debt incurred during the course and scope of the patient’s employment and subject to Florida’s Worker’s Compensation Act, is not considered a consumer debt under the FDCPA?