The FDCPA itself contains numerous exceptions to the definition of a "debt collector", particularly after the October 13, 2006, passage of the Financial Services Regulatory Relief Act of 2006.
The FDCPA's definitions of "consumers" and "debt" specifically restricts the coverage of the act to personal, family or household transactions.
[33] However, under the sweeping reforms of the 2010 Dodd-Frank Act, the FDCPA is enforced primarily by the Consumer Financial Protection Bureau.
[38] Some consumer groups argue that the FDCPA does not go far enough, and does not provide sufficient deterrence against unscrupulous collection agencies.
Consumer groups have complained that the maximum statutory damages contained in the original 1977 version of the law has not kept up with inflation;[citation needed] $1,000 in 1977 dollars is worth $5028 as of 2023.
[39] Conversely, many in the credit industry and some courts have taken the stance that the FDCPA has often been used to file frivolous lawsuits and seek damages for minor technical violations and has, at times, seriously impeded their ability to collect valid debts.
[42] The accounts receivable management industry has also raised concerns that the FDCPA contains contradictions that often lead to liability on the part of collection agencies in civil cases, especially when dealing with technology that did not exist when the law was written.
[43] For its part, the Federal Trade Commission (FTC) produces an annual report to Congress of its findings with respect to its FDCPA enforcement activities.
This report details consumer complaints to the FTC about alleged debt collector violations of the FDCPA.
[45] The FTC has authority to issue formal opinions regarding debt collectors' conduct under the FDCPA,[46] but the Dodd-Frank Wall Street Reform and Consumer Protection Act transfers authority for rule making to the new Consumer Financial Protection Bureau (CFPB) effective between January 21, 2011 and July 21, 2011.