In Midland Funding, LLC v. Johnson, the SCOTUS held that allowing bankrupt debtors to invoke the FDCPA would upset a “delicate balance” and “authorize a new significant bankruptcy-related remedy in the absence of language in the [Bankruptcy] Code providing for it.” Instead, barring debt collectors from filing stale claims would require creditors to investigate the merits of affirmative defenses. “The upshot could well be added complexity, changes in settlement incentives and a shift from the debtor to the creditor the obligation to investigate the staleness of a claim.”