Consumer Law Hinsights is a monthly compilation of nationwide consumer protection cases of interest to financial services and accounts receivable management companies. Eleventh Circuit Delivers Surprising Decision on Use of Third-Party Vendors in FDCPA Case The district court dismissed the case for lack of standing and Hunstein appealed. The Eleventh Circuit concluded that the requirements of standing could be met in one of three ways: 1) tangible harm in the form of physical injury, financial loss, or emotional distress; 2) a risk of real harm requiring factual allegations that establish substantial, significant, or real danger; and 3) statutory violations. The court found that while Hunstein failed to establish either tangible harm or risk of real harm, he did establish a statutory violation that granted him standing. Their statutory violation analysis involved looking at "history and the judgment of Congress." The court took a very textualist view of the law and surprisingly held that providing information about the plaintiff and the debt to a third-party letter vendor was an impermissible disclosure to a third party in violation of the FDCPA.A Fair Debt Collection Practices Act (FDCPA) decision from the Middle District of Florida was appealed to the Eleventh Circuit where it was recently reversed and remanded. The plaintiff, Richard Hunstein, sued Preferred Collection and Management Services, Inc. for allegedly violating 15 U.S.C. § 1692c(b) that prohibits a debt collector from sharing information about an outstanding debt to anyone but a specific set of enumerated parties. As is commonplace, Preferred sent information about plaintiff and the debt to its letter vendor as part of their collection process, and Hunstein brought suit.