2010 and the Department of Housing and Urban Development’s Secure and Fair Enforcement for Mortgage Licensing Act Rule issued in June 2011. (4) Also consistent with the principle of judicial regulation of attorneys and the legal profession, Congress has generally declined to enact legislation regulating the practice of law, including litigation activities of attorneys. (5) Congress has also incorporated broad practice of law exclusions into certain Federal statutes. For example, section 1027(e) of the Consumer Financial Protection Act of 2010 excludes most attorneys engaged in the practice of law from the Consumer Financial Protection Bureau’s regulatory and enforcement authority, while the Fair Debt Collection Practices Act of 1977 originally contained a complete exemption for attorneys engaged in the practice of law. (6) Although Congress removed the complete attorney exemption from the Fair Debt Collection Practices Act in 1986 based in part on its belief that the revised Act would only apply to attorneys’ non-litigation collection activities and that State courts would continue to regulate attorneys’ litigation activities, the United States Supreme Court held in Heintz v. Jenkins, 514 U.S. 291 (1995), that attorneys could be subject to the Act even when they are engaged in litigation activities. As a result, many attorneys now are routinely sued for litigation activities in State court that are alleged to be technical violations of the Act, even when consumers suffer no harm. (7) In each of its annual reports to Congress on the Fair Debt Collection Practices Act from 1998 through 2006, the Federal Trade Commission formally recommended that Congress reexamine and amend the definition of debt collector in the Act to exempt attorneys who pursue debtors solely through litigation (or similar legal practices). (8) In recent years, the Consumer Financial Protection Bureau has also aggressively sought to regulate attorneys’ collection activities, including their litigation activities, despite the broad practice of