Debt Collector Pseudonyms

Story here about debt collectors using pseudonyms because of the abuse they get. I don't doubt it. Debt collectors aren't exactly popular folks. I was recently searching for cartoons of various consumer finance topics and there were by far the most about debt collectors, none flattering. But I don't think that makes it ok for a debt collector to use a pseudonym.

I think using a pseudonym might itself violate the Fair Debt Collection Practices Act.  The FDCPA prohibits "any false, deceptive, or misleading representation or means in connection with the collection of any debt," including "The use of any false representation or deceptive means to collect or attempt to collect any debt or to obtain information concerning a consumer."

I'm not sure that a consumer is likely to be harmed in any way by a debt collector using a pseudonym like John Smith, but perhaps use of a pseudonym emboldens debt collectors to be more aggressive. Remember, the Fair Debt Collection Practices Act has multiple provisions to protect debtors from abuse by debt collectors. (Hey, there's that "abuse" term that has everyone so worried in the Consumer Financial Protection Act...)

Of course, there's a wee enforcement problem--how does one know if a debt collector is using a pseudonym, unless it's something like "Barack Obama"? (Impersonating a government official is itself an FDCPA violation.)