of General Policy or Interpretation Staff Commentary on the Fair Debt Collection Practices Act, 53 Fed.Reg. 50,097, 50,102 (Dec. 13, 1988). The agency’s commentary “is based primarily on issues discussed in informal staff letters responding to public requests for interpretations and on the Commission’s enforcement program,” id. at 50,101, and does not receive Chevron deference, see United States v. Mead Corp., 533 U.S. 218, 234, 121 S.Ct. 2164, 150 L.Ed.2d 292 (2001). But the commentary is entitled to “respectful consideration.” Carter, 645 F.3d at 844. Apparently the question whether fines are “debts” under the FDCPA has never arisen in a court of appeals (at least not in a precedential decision). Yet that issue has come up f 6-cv-400, 2008 WL 782540, at *5 (E.D.Tenn. Mar. 20, 2008) (<HOLDING>), aff'd on other grounds, 582 F.3d 617 (6th
holding that back rent is debt under the fdcpa holding that unpaid traffic fine is not debt under fdcpa holding that the name under which a debt collector is licensed to do business is the debt collectors true name for purposes of the fdcpa holding that an entity engaged in collection activity on a defaulted debt acquired from another is a debt collector under the fdcpa even though it may actually be owed the debt holding that debt under the fdcpa is limited to liability arising out of consensual consumer transactions and not tortious activity