19.  At all relevant times, Plaintiff had a deposit account with San Diego  County Credit Union (the “Account”).   2.    Authorization obtained by third party. The account-holding  financial institution does not violate the regulation when a third-party  payee fails to obtain the authorization in writing or fails to give a copy to  the consumer; rather, it is the third-party payee that is in violation of the  regulation.   20.  The Account was established primarily for personal, family, or household  purposes, and thus, is an “account” as defined by 15 U.S.C. §1693a(2).   21.  On or about May 18, 2015, Defendant sent a written communication to  Plaintiff in connection with the collection of the Debt.  A true and correct copy of the  May 18, 2015 communication to Plaintiff is attached hereto as Exhibit A.   22.  The May 18, 2015 written communication advised Plaintiff that she owed  a debt to Paypal Inc. in the amount of $2,937.38.   24.  The May 18, 2015 written communication then encouraged Plaintiff to  call Defendant or mail payment to its office if she was “interested in taking advantage  of this offer….”  Id.    25.  On or about May 29, 2015, Plaintiff called Defendant in response to the  May 18, 2015 written communication.     26.  During the call, Defendant solicited from Plaintiff over the telephone  information about the Account in order to initiate recurring transfers for payments  toward the Debt.     27.  Plaintiff and Defendant then agreed, orally, that Defendant would  electronically transfer $30.00 from the Account each month for four consecutive  months (the “EFT Agreement”).      28.  Defendant did not obtain from Plaintiff written authorization for the EFT  Agreement.  Plaintiff has not authorized, in writing, any of the preauthorized  electronic fund transfers from the Account.    29.  Defendant did not provide Plaintiff with a copy of any document which  Plaintiff signed authorizing the EFT Agreement or the preauthorized electronic fund  transfers.    31.  Upon information and belief, Defendant has taken electronic fund  transfers from the accounts of numerous other consumers throughout California, on  regularly scheduled intervals, without written authorization, and without providing a  copy of such authorization to those consumers.  33.  Upon information and belief, the proposed Classes are so numerous that  joinder of all members is impracticable.  The exact number of members of the Classes  is unknown to Plaintiff at this time and can only be ascertained through appropriate  discovery.  The proposed Classes are ascertainable in that, upon information and  belief, the names and addresses of all members of the Classes can be identified in  business records maintained by Defendant.      34.  Plaintiff’s claims are typical of the claims of the members of the Classes  because Plaintiff and all Class members’ claims originate from the same conduct,  practice and procedure on the part of Defendant and Plaintiff has suffered the same  injuries as each member of the Classes.  Like all proposed members of the Classes,  Plaintiff entered into an oral preauthorized electronic fund transfer agreement with  Defendant that was not authorized by a writing signed or similarly authenticated by  Plaintiff.    35.  Plaintiff will fairly and adequately protect the interests of the members of  the Classes and has retained counsel experienced and competent in class action  litigation.     37.  Issues of law and fact common to the members of the Classes  predominate over any questions that may affect only individual members, in that  Defendant has acted on grounds generally applicable to the Classes.  Among the  issues of law and fact common to the Classes are:  a. Defendant’s failure to obtain from Plaintiff and other members of the  Classes written authorization to electronically transfer funds on a  recurring basis from their bank accounts;  b. Defendant’s failure to provide Plaintiff and other members of the Classes  with a copy of any document which they signed authorizing the  electronic fund transfers.   c. the availability of declaratory relief;  d. the availability of statutory penalties; and  e. the availability of attorneys’ fees and costs.   39.  Plaintiff repeats and re-alleges each and every factual allegation  contained in paragraphs 1 - 38.   40.  15 U.S.C. § 1693e(a) provides, in pertinent part:  A preauthorized electronic fund transfer from a consumer’s account may  be authorized by the consumer only in writing, and a copy of such  authorization shall be provided to the consumer when made.   (emphasis added).    41.  12 C.F.R. § 1005.10(b) provides, in pertinent part:  Written authorization for preauthorized transfers from consumer’s  account. Preauthorized electronic fund transfers from a consumer’s  account may be authorized only by a writing signed or similarly  authenticated by the consumer. The person that obtains the authorization  shall provide a copy to the consumer.    (emphasis added).   42.  The Official Staff Interpretations to the EFTA, at 12 C.F.R. Pt.  1005.10(b), Supp. I, provide, in pertinent part:   43.  The EFT Agreement was not authorized by a writing signed or similarly  authenticated by Plaintiff.  Rather, Defendant purportedly obtained authorization from  Plaintiff verbally, never obtaining a writing from Plaintiff authorizing the  preauthorized electronic fund transfers.  Further, as there was no signed agreement  authorizing the transfers, Defendant never provided a copy of the signed, written  agreement to Plaintiff.    44.  Thus, Defendant violated 15 U.S.C. § 1693e(a) and 12 C.F.R. §  205.10(b).  45.  Plaintiff repeats and re-alleges each and every factual allegation  contained in paragraphs 1-38.   46.  The FDCPA at 15 U.S.C. §1692 f provides that “[a] debt collector may  not use unfair or unconscionable means to collect or attempt to collect any debt.”    48.  Thus, Defendant violated 15 U.S.C. § 1692f.  6.  Requirements of an authorization. An authorization is valid if it is  readily identifiable as such and the terms of the preauthorized transfer  are clear and readily understandable.  (emphasis added).   AS TO PLAINTIFFS AND THE FDCPA CLASS   REGULATION E, 12 C.F.R. § 1005.10(b)   AS TO PLAINTIFF AND THE EFTA CLASS  