ACA International, “New Jersey Appeals Court Upholds Victory for Unifund CCR,” quotes Richard J. Perr, Esq., 11-6-2025

Kaufman Dolowich’s Richard J. Perr, Co-Chair of KD’s Financial Services and Institutions Practice Group and Co-Managing Partner of the firm’s Philadelphia office, was quoted in an ACA International article regarding a case ruling that could have significant implications for debt collection and compliance standards within the state of New Jersey.

The New Jersey Appellate Division in its ruling affirmed that consumers cannot wait years to challenge judgments they have already satisfied. The decision in Unifund CCR LLC v. Garabedian reinforces critical principles of judicial finality while clarifying the limits of consumer challenges under state licensing laws.

In this case, the Plaintiff argued her debt was void because the intermediate debt buyers lacked required licenses under New Jersey’s Consumer Finance Licensing Act (NJCFLA). But the court ultimately held that the NJCFLA provides no private right of action for consumers.

Mr. Perr in the article is quoted as saying, “this is a fatal flaw in plaintiffs’ entire series of litigation under the act,” particularly since as a matter of law, none of the underlying debts can be voided before the Commissioner of Banking and Insurance makes such a determination. Further, he stated, “and if the debts are not void, then none of the collection activity violates the FDCPA.”

Read the full article here.