the Fair Debt Collection Act is entirely without merit, as the statute expressly excludes 'any officer or employee of the United States ... to the extent that collecting or attempting to collect any debt is in the performance of his official duties' from the definition of 'debt collector'. 15 U.S.C. section 1692a(6)(C)." In 1998, however, Congress amended the Internal Revenue Code by adding a new section 6304, "Fair Tax Collection Practices", which refers to and includes certain rules that are similar to some provisions of the Fair Debt Collection Practices Act. In Henson v. Santander Consumer USA Inc., the Supreme Court excluded collection companies that purchase consumer debt from the FDCPA when it unanimously held that a company may collect debts that it purchased for its own account without triggering the statutory definition of a "debt collector" under the Fair Debt Collection Practices Act. Nonetheless, at least one subsequent Circuit Court opinion has cabined the impact of Henson by subsequently finding that companies that purchase consumer debt could still be subject to the FDCPA under the alternative definition of debt collector as a business whose "principal purpose" is the collection of debts. Prohibited conduct The Act prohibits certain types of "abusive and deceptive" conduct when attempting to collect debts, including the following: Hours for phone contact: contacting consumers by telephone outside of the hours of 8:00 a.m. to 9:00 p.m. local time. Additionally, if certain hours are inconvenient for consumers during the allowable time (those who work at night and sleep during the day) they may not be contacted during those times. Failure to cease communication upon request: communicating with consumers in any way (other than litigation) after receiving written notice that said consumer wishes no further communication or refuses to pay the alleged debt, with certain exceptions, including advising that collection efforts are being terminated or that the collector intends to file a lawsuit or pursue other remedies where permitted. Causing a telephone to ring or engaging any person in telephone conversation repeatedly or continuously: with intent to annoy, abuse, or harass any person at the called number. Communicating with consumers at their place of employment after having been advised that this is unacceptable or prohibited by the employer. Contacting a consumer known to be represented by an attorney. The collector must contact the attorney instead, unless the attorney is unresponsive or consents to the client's being contacted directly.