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79 depend. at is not the situation in Hunstein. e court recognizes its ruling "may well require debt collectors … to in-source many of the services that they had previously outsourced, potentially at great cost." e court goes on to note that its "obligation is to interpret the law as written, whether or not we think the resulting consequences are particularly sensible or desirable." e 11th Circuit's decision is only binding in Alabama, Florida, and Georgia. However, since the court indicated that this is an issue of first impression, it is very likely that Federal Courts of Appeals covering other states may adopt the same approach in evaluating the inevitable lawsuits on this issue. It remains to be seen whether arguments regarding agency and/or severe services contract limitations on the use of information will be considered to mitigate claims of violation. As a result, loan servicers and debt collectors should evaluate each third-party vendor relationship utilized in relation to interaction with or about a debtor. For residential loan servicers, this may include call center vendors, business process outsourcing vendors assisting in the processing of modification requests and, clearly, print and mail vendors. Fortunately, the initial transfer of information to counsel for the debt collector would be exempt under the plain language of the statute. However, any further transfers of information by the debt collector's counsel to a subsequent vendor would be subject to scrutiny under Hunstein. ere is no longer an attorney exemption to the federal FDCPA's definition of debt collector (and California recently eliminated its attorney exemption to the Rosenthal FDCPA). us, counsel for the debt collector itself may be deemed a debt collector under federal or state definitions of a debt collector, subjecting the transfer of information by the law firm to a third-party vendor to potential coverage as well. Brett L. Foster recently joined Wright, Finlay & Zak as Of Counsel. For over 25 years, his practice has focused on the business and regulatory compliance issues faced by banks, credit unions, and mortgage bankers. Foster has extensive experience advising clients on residential and commercial mortgage lending operations and licensing, payments, and vendor engagement across numerous financial services platforms. Michelle A. Mierzwa joined Wright, Finlay & Zak's Compliance, Licensing, and Regulatory Division in 2015, providing loan originators, lenders, servicers, trustees, and others in the mortgage industry with state and federal compliance and regulatory counsel. Since 1998, her accomplishments include the management and resolution of litigated matters through jury and bench trials and appellate practice, creating the legal department for one of the largest non-judicial foreclosure trustees in the Western United States, the coordination of compliance audits, and managing the California branch of a national law firm.