I wish I had a clear and solid answer for you, but I don't.
I have done lots of research on this- and these JDB's are using the federal FDCPA for debt collection and state laws as an OC.
They think they are creditors and not "debt collectors" and here in AZ they have managed to get away with this for sometime. I have raised a HUGE stink with AZDFI and am just starting to get results.
They are not on my reports, I am helping others.
My advice is to dig though your state statues-