EFFECTIVE DEMAND LETTERS - NACM
credit cardholder violated business cardholder agreement by incurring personal debt, she incurred consumer “debt,” subject to FDCPA; debt was personal at moment it was incurred) •First Gibraltar Bank, FSB v. Smith, 62 F.3d 133 (5th Cir. 1995) (obligations arising out of commercial transaction is not debt under the FDCPA) •Garza v.
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