10.  On or around October, 27, 2014, Plaintiff and Defendant agreed to  settle the debt for $1,554.30 over the phone   11.  Without written permission from Plaintiff, Defendant withdrew  money from Plaintiff’s account multiple times.   12.  In or around October of 2014, Plaintiff began to notice re-occurring  charges being deducted from his personal banking account by Defendant.   13.  On October 27, 2014, Defendant first deducted $499 from Plaintiff’s  account, then $501 from Plaintiff’s account, and then finally another $554.30.   14.  After some investigation, Plaintiff discovered that Defendant was  deducting sums from his account in order to make payments towards the orally  agreed settlement agreement.   15.  Plaintiff never provided Defendant with any written authorization to  deduct any sums of money on a regular recurring basis from Plaintiff’s banking  account.   19.  Plaintiff brings this action on behalf of himself and all others  similarly situated, as a member of the proposed class (hereafter “The Class”)  defined as follows:  All persons in the United States whose bank accounts  were debited on a reoccurring basis by Defendant  without Defendant obtaining a written authorization  signed or similarly authenticated for preauthorized  electronic fund transfers within the one year prior to the  filing of this Complaint.   20.  Plaintiff represents, and is a member of, The Class, consisting of all  persons within the United States whose bank account was debited on a recurring  basis by Defendant without Defendant obtaining a written authorization signed or  similarly authenticated for preauthorized electronic fund transfers within the one  year prior to the filing of this Complaint.   21.  Defendant, their employees and agents are excluded from The Class.   Plaintiffs do not know the number of members in The Class, but believe the Class  members number in the hundreds, if not more.  Thus, this matter should be  certified as a Class Action to assist in the expeditious litigation of the matter.   43.  Section 907(a) of the EFTA, 15 U.S.C. §1693e(a), provides that 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.”   44.  Section 903(9) of the EFTA, 15 U.S.C. § 1693a(9), provides that the  term “preauthorized electronic fund transfer” means “an electronic fund transfer  authorized in advance to recur at substantially regular intervals.”   45.  Section 205.l0(b) of Regulation E, 12 C.F.R. § 205.l0(b), provides  that “[p]reauthorized 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.”   46.  Section 205.10(b) of the Federal Reserve Board's Official Staff  Commentary to Regulation E, 12 C.F.R. § 205.l0(b), Supp. I, provides that “[t]he  authorization process should evidence the consumer’s identity and assent to the  authorization.”  Id. at ¶10(b), comment 5.  The Official Staff Commentary further  provides that “[a]n authorization is valid if it is readily identifiable as such and  the terms of the preauthorized transfer are clear and readily understandable.”  Id.  at ¶10(b), comment 6.   9.  Starting on or around 2014, Plaintiff was contacted by Defendant in  relation to an alleged debt.     DEFENDANT VIOLATED THE ELECTRONIC FUNDS TRANSFER  ACT  (On Behalf of Plaintiff and the Class)   