What still controls: Reyes v. Steeg Law

The question Mississippi associations most often need answered is whether the law firm that sends assessment demand letters and files liens is a “debt collector” under the Fair Debt Collection Practices Act — because if it is, a long list of notice, validation and conduct requirements attaches, and violations carry statutory damages.

The controlling Fifth Circuit authority is Reyes v. Steeg Law, L.L.C., No. 17-30849 (5th Cir. Jan. 17, 2019), and it came out of a Louisiana condominium association case.²

The court refused to adopt a bright-line rule. It looked instead at whether the firm “regularly” collected debts, measured by volume and by the business's shape: 36 letters and 34 liens in a year, 1.3% of firm revenue and 1.5% of billable hours attributable to association collections. On those facts the firm was not regularly collecting debts and was outside the statute.

That is a fact-intensive test, and its practical effect is that the answer depends on the particular firm rather than on the activity. A general-practice firm handling occasional association matters is likely outside it; a firm whose practice is association collections is not.

Why the silence is itself worth knowing

Mississippi has no statutory assessment lien. An association's collection rights come from the recorded declaration, from the Mississippi Nonprofit Corporation Act, and from general judgment-lien and foreclosure procedure. In a state where the substantive law is that thin, federal decisions construing what collectors may do carry proportionately more weight — and there have not been any.

The one Mississippi federal case on the docket is instructive about what these cases look like when they do appear. Stant v. Turtle Creek Homeowners' Association, Inc., No. 1:26-cv-00022 (S.D. Miss.), was filed January 21, 2026 as a federal-question civil-rights matter before Chief Judge Ozerden, and dismissed without prejudice on May 28, 2026 for a purely procedural reason: the docket order records that the claims were dismissed “for lack of legal capacity to proceed pro se on behalf of the Estate.” There is no merits holding on anything HOA-related.

What it means for a Mississippi board

Ask your collection counsel where they sit on the Reyes factors. A firm that does association collections as a substantial share of its practice has reason to operate as if the FDCPA applies, and its posture is something a board can find out.

Validation notices cost nothing to send. Where the answer is uncertain, compliance is cheap and non-compliance carries statutory damages.

The association can have its own exposure. The FDCPA generally reaches third-party collectors rather than creditors collecting their own debts, but an association that collects through an entity structured to look like a collector, or that uses a management company's collection arm, should understand which side of that line it is on.

What to watch next

Nothing is pending. The next Fifth Circuit word on association collections will most likely arrive the way Reyes did — out of a Louisiana condominium dispute, applying to Mississippi by circuit precedent rather than by anything a Mississippi court or legislature decided.