Nah, it's the exact opposite. The FDCPA is clear and violations are obvious. That is why the collection agencies settle. Litigation would not only be costly, it would be costly and futile when the collector inevitably loses.

The FDCPA, formally, 15 U.S.C s. 1692 et seq., is abundantly clear about what activities are forbidden. There is some legal jargon in it, but it is clearly written. If anyone cares to read it, it is less than 20 pages long.

The FDCPA does not leave violations open to interpretation. It explicitly lists false representations and unfair practices that are unlawful, including such unambiguous things as 1) Claiming the debt collector is affiliated with the government, 2) Claiming the debtor has committed a crime, 3) Claiming that a debt that the statute of limitation ran out on can still be sued on, 4) Not putting certain notices in collections letters; said notices are provided using the exact words that are compliant (enabling cut-and-paste compliance), 5) Threatening to sue when you do not intend to sue, etc.

Mostly, obvious things like this are the kind of violations that debt collectors actually commit. Note that they are often the most efficient collection methods, because they terrify people or leave them ignorant of their rights. Without the law, every collection agency / law firm would be forced to use these techniques in order to compete. That would mean many consumers would be terrified out of their wits, instead of having the mildly unpleasant experience of interacting over the phone with used-car-salesman types.

I think most collection agencies and collection firms are aware of the law and actively avoid doing this stuff. The ones that violate the FDCPA are not doing so because the law is outdated and hard to understand. Their behavior is an intentional choice or willful ignorance.

You want outdated and hard to understand? That would be the various patchwork of laws regulating telephone calls.