Debt Collection ‘versus’ Consumer Protection: The FDCPA’s Prohibition on False Representations of the Legal Status of Debt

(Excerpt) The Fair Debt Collection Practices Act (“FDCPA”), 15 U.S.C. § 1692, has dramatically changed the landscape of debt collection for both consumers and debt collectors. Prior to the enactment of the FDCPA, state common law governed informal debt collection, and abusive collection practices were pervasive. Debt collectors were incentivized to engage in abusive collection tactics and consumers had little recourse. As a result, the FDCPA was enacted in order to regulate consumer debt collection and to remedy abuse. The express purpose of the FDCPA is to “protect consumers against debt collection abuses” and to ensure that debt collectors who refrain from abuse are not competitively disadvantaged. Specifically, 15 U.S.C.§ 1692e prohibits the “false, deceptive, or misleading representation or means in connection with the collection of any debt.” Recently, misleading debt collection practices have been the subject of significant litigation. In particular, the In re Murray litigation raised the issue of whether “versus language” in a debt collection letter violated the FDCPA. In assessing FDCPA claims, courts construe the statute liberally in favor of consumers, subjecting debt collectors to greater potential liability. Therefore, understanding the bounds of the FDCPA, and situations that lead to its violation, is crucial to preventing liability. Moreover, such an understanding is essential to redressing abuse. Thus, the central issue that must be addressed is: when are debt collection practices “false, deceptive, or misleading” in violation of the FDCPA and what are the requisite legal standards to assess such violations. This article will explore the present question in three parts. Part I examines the legal standards that federal courts utilize to determine FDCPA violations. Part II addresses the permissibility of versus language in a debt collection letter under 15 U.S.C. § 1692e(2)(A). Part III analyzes collection tactics that violate 15 U.S.C. § 1692e(13) and whether versus language in the debt collection letter triggers a violation

Nanomedicine: promises and challenges for the future of public health

As the scope of nanotechnology applications in medicine evolves, it is important to simultaneously recognize and advance contributions germane to public health. A wide range of innovations in nanomedicine stand to impact nearly every medical specialty and unveil novel ways to improve the quality and extend the duration of life – these gains can be measured at both individual and population levels. For example, heart disease and cancer combined make up approximately half of all deaths in the United States per year, and already, advances in nanomedicine demonstrate great potential to reduce rates of morbidity and mortality due to these diseases. Meanwhile, public health applications of nanomedicine such as rapid and portable diagnostics and more effective vaccinations have the potential to revolutionize global health. Research driven by innovators across disciplines such as engineering, biology, medicine, and public health should collaborate in order to achieve maximal potential impact in health for individuals and populations. In turn, knowledge gaps regarding the potential health and safety implications of exposure to engineered nanomaterials must be continuously addressed and actively researched. Dynamic, proactive, and socially responsible research will drive nanomedicine as it plays an increasingly integral and transformative role in medicine and public health in the 21st century

Internal Culture, External Impact: How a Change-Making Culture Positions Foundations to Achieve Transformational Change

This article argues that a foundation’s internal culture is critical to achieving large-scale social change, but that efforts to build a change-making culture too often are left out of strategy conversations. While there is no one culture that suits every foundation, a particular set of characteristics must be present in those that seek large-scale social change: a focus on outcomes, transparency, authenticity, collaboration, racial equity and inclusion, continuous learning, and openness to risk. This article offers insights into why culture can be challenging for foundations to address and maintain, examines cases of successful culture change at foundations, and offers advice for foundations that aspire to it

Principals\u27 Perceptions about Alternate Route Programs in Rural Areas

Alternate route programs are increasingly serving schools in rural areas that may struggle to recruit new teachers. In this study, ten principals of middle schools from rural areas of Mississippi were interviewed regarding their perceptions of alternate route programs’ recruitment, selection, preparation, mentorship, support, and retention practices. Qualitative analysis of semi-structured interviews suggests that principals of rural schools had limited experience with alternatively certified teachers and, overall, their views were generally positive. They believed that these programs would help meet the high need for teachers in the state, and alternate route candidates may provide benefits to middle school students due to their greater content knowledge, experience, and maturity. However, they also held concerns regarding the absence of student teaching, alternatively certified teachers’ readiness for the classroom, and the amount and quality of support and mentoring in the first year of teaching

An analysis of technology gaps and priorities in support of probe-scale coronagraph and starshade missions

This paper provides a survey of the state-of-the-art in coronagraph and starshade technologies and highlights areas where advances are needed to enable future NASA exoplanet missions. An analysis is provided of the remaining technology gaps and the relative priorities of technology investments leading to a mission that could follow JWST. This work is being conducted in support of NASAs Astrophysics Division and the NASA Exoplanet Exploration Program (ExEP), who are in the process of assessing options for future missions. ExEP has funded Science and Technology Definition Teams to study coronagraphs and starshade mission concepts having a lifecycle cost cap of less than $1B. This paper provides a technology gap analysis for these concepts

Primary Alcohol-Activated Human and Mouse Hepatic Stellate Cells Share Similarities in Gene-Expression Profiles.

Alcoholic liver disease (ALD) is a leading cause of cirrhosis in the United States, which is characterized by extensive deposition of extracellular matrix proteins and formation of a fibrous scar. Hepatic stellate cells (HSCs) are the major source of collagen type 1 producing myofibroblasts in ALD fibrosis. However, the mechanism of alcohol-induced activation of human and mouse HSCs is not fully understood. We compared the gene-expression profiles of primary cultured human HSCs (hHSCs) isolated from patients with ALD (n = 3) or without underlying liver disease (n = 4) using RNA-sequencing analysis. Furthermore, the gene-expression profile of ALD hHSCs was compared with that of alcohol-activated mHSCs (isolated from intragastric alcohol-fed mice) or CCl4-activated mouse HSCs (mHSCs). Comparative transcriptome analysis revealed that ALD hHSCs, in addition to alcohol-activated and CCl4-activated mHSCs, share the expression of common HSC activation (Col1a1 [collagen type I alpha 1 chain], Acta1 [actin alpha 1, skeletal muscle], PAI1 [plasminogen activator inhibitor-1], TIMP1 [tissue inhibitor of metalloproteinase 1], and LOXL2 [lysyl oxidase homolog 2]), indicating that a common mechanism underlies the activation of human and mouse HSCs. Furthermore, alcohol-activated mHSCs most closely recapitulate the gene-expression profile of ALD hHSCs. We identified the genes that are similarly and uniquely up-regulated in primary cultured alcohol-activated hHSCs and freshly isolated mHSCs, which include CSF1R (macrophage colony-stimulating factor 1 receptor), PLEK (pleckstrin), LAPTM5 (lysosmal-associated transmembrane protein 5), CD74 (class I transactivator, the invariant chain), CD53, MMP9 (matrix metallopeptidase 9), CD14, CTSS (cathepsin S), TYROBP (TYRO protein tyrosine kinase-binding protein), and ITGB2 (integrin beta-2), and other genes (compared with CCl4-activated mHSCs). Conclusion: We identified genes in alcohol-activated mHSCs from intragastric alcohol-fed mice that are largely consistent with the gene-expression profile of primary cultured hHSCs from patients with ALD. These genes are unique to alcohol-induced HSC activation in two species, and therefore may become targets or readout for antifibrotic therapy in experimental models of ALD

Testing the Indirect Effect of Type 1 Diabetes on Life Satisfaction Through Self-Compassion and Self-Coldness

Objectives Diabetes is a chronic disease that markedly affects the daily life of individuals and lowers subjective well-being. Selfcompassion, or treating oneself with kindness and acceptance during challenging circumstances, may improve subjective wellbeing among people with diabetes. In the current study, we explored the relationships between duration of diabetes, positive and negative components of self-compassion (i.e., self-compassion and self-coldness), and life satisfaction. Methods The sample consisted of 112 persons with type 1 diabetes. A Self-Compassion Scale and Satisfaction with Life Scale were used. Results A parallel multiple mediation model revealed that diabetes duration was related to lower self-coldness but not to selfcompassion. Both self-coldness and self-compassion strongly correlated with life satisfaction. Diabetes duration demonstrated a significant indirect effect on life satisfaction through self-coldness (b = 0.08, 95% CI [0.01, 0.16]), but not through selfcompassion (b = 0.00, 95% CI [− 0.06, 0.06]). Conclusions The study suggests the need to examine the positive and negative components of the Self-Compassion Scale separately when studying well-being of persons with type 1 diabetes, as well as to prepare tailored self-compassion and selfcoldness interventions that can be adjusted for people with varying diabetes durations

Early prediction of histopathological response of rectal tumors after one week of preoperative radiochemotherapy using 18 F-FDG PET-CT imaging. A prospective clinical study

BACKGROUND: Preoperative radiochemotherapy (RCT) is standard in locally advanced rectal cancer (LARC). Initial data suggest that the tumor’s metabolic response, i.e. reduction of its (18) F-FDG uptake compared with the baseline, observed after two weeks of RCT, may correlate with histopathological response. This prospective study evaluated the ability of a very early metabolic response, seen after only one week of RCT, to predict the histopathological response to treatment. METHODS: Twenty patients with LARC who received standard RCT regimen followed by radical surgery participated in this study. Maximum standardized uptake value (SUV-MAX), measured by PET-CT imaging at baseline and on day 8 of RCT, and the changes in FDG uptake (ΔSUV-MAX), were compared with the histopathological response at surgery. Response was classified by tumor regression grade (TRG) and by achievement of pathological complete response (pCR). RESULTS: Absolute SUV-MAX values at both time points did not correlate with histopathological response. However, patients with pCR had a larger drop in SUV-MAX after one week of RCT (median: -35.31% vs −18.42%, p = 0.046). In contrast, TRG did not correlate with ΔSUV-MAX. The changes in FGD-uptake predicted accurately the achievement of pCR: only patients with a decrease of more than 32% in SUV-MAX had pCR while none of those whose tumors did not show any decrease in SUV-MAX had pCR. CONCLUSIONS: A decrease in ΔSUV-MAX after only one week of RCT for LARC may be able to predict the achievement of pCR in the post-RCT surgical specimen. Validation in a larger independent cohort is planned

Fine-mapping identifies multiple prostate cancer risk loci at 5p15, one of which associates with TERT expression

Associations between single nucleotide polymorphisms (SNPs) at 5p15 and multiple cancer types have been reported. We have previously shown evidence for a strong association between prostate cancer (PrCa) risk and rs2242652 at 5p15, intronic in the telomerase reverse transcriptase (TERT) gene that encodes TERT. To comprehensively evaluate the association between genetic variation across this region and PrCa, we performed a fine-mapping analysis by genotyping 134 SNPs using a custom Illumina iSelect array or Sequenom MassArray iPlex, followed by imputation of 1094 SNPs in 22 301 PrCa cases and 22 320 controls in The PRACTICAL consortium. Multiple stepwise logistic regression analysis identified four signals in the promoter or intronic regions of TERT that independently associated with PrCa risk. Gene expression analysis of normal prostate tissue showed evidence that SNPs within one of these regions also associated with TERT expression, providing a potential mechanism for predisposition to disease