It seems clear that the FDCPA does NOT cover officers or employees of the United States. So my question is: Are AG employees--namely civil collection specialists working within the AG's office--considered to be employees of the United States who are not bound by the FDCPA?
Well, my answer would be... The answer depends... If they are actual employees of the AG's office, then they would be covered by the exemption. If they are employees of a third-party CA, BUT they are immediately supervised by the AG's office supervisors, they could be covered by the exemption. If they are employees of a third-party CA, but they are not supervised by the AG's office (the third-party CA basically runs them independent of the AG's office), then they may not be covered by the exemption. This would be utilizing the precident of determining who qualifies for the OC exemption. It depends on who is actually in control of the employees.
