California Governor Jerry Brown recently signed a bill amending the Rosenthal Fair Debt Collection Practices Act and the California Code of Civil Procedure. The new law, which takes effect January 1, requires disclosures in any communication by a debt collector attempting to collect a time-barred debt. Because the RFDCPA defines the term "debt collector" to include first-party creditors in addition to third-party creditors, auto dealers and finance companies should pay attention.

On May 15, 2017, in the case of Midland Funding, LLC v. Johnson, the U.S. Supreme Court held in a 5-3 decision (Justice Gorsuch did not participate in the opinion) that a debt collector that files a proof of claim on a time-barred debt in a consumer bankruptcy does not violate the Fair Debt Collection Practices Act.