Galvan Ex Rel. Galvan v. NCO Portfolio Management, Inc.

SYKES, Circuit Judge.

For 40 years Illinois regulators and debt collectors have played a kind of cat-and-mouse game. The legislature has gradually expanded the scope of the business activities that trigger the requirements of the Illinois Collection Agency Act (“ICAA” or “the Act”), 225 III. Comp. Stat. 425/1 et seq., and the industry has responded by finding ways to do business without engaging in those activities. The question in this case is whether passive debt buying was covered by the Act before the most recent revision in 2013. The district court said “no,” but the Illinois Supreme…