(December 14, 2023, 2:09 PM EST) -- ATLANTA — A mortgagor’s Fair Debt Collection Practices Act (FDCPA) claims against his mortgage servicer based on statements made by that company’s representative as part of a foreclosure action more than a year after it was first filed were time-barred as the statements were “not independently actionable” under the FDCPA, an 11th Circuit U.S. Court of Appeals panel ruled....