2nd Cir. Holds Payoff Statement Stating ‘Amount Due May Include’ Estimated Fees, Costs Violates FDCPA


The U.S. Court of Appeals for the Second Circuit recently reinstated a complaint alleging a debt collector violated the federal Fair Debt Collection Practices Act when it sent a payoff statement containing unaccrued fees and costs without providing any information as to how those fees were calculated or any basis for those fees and costs.