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Second Circuit Holds No Need to Identify Components of Debt Where Collection Letter Provides Exact Amount Owed and Reaffirms Use...

In Kolbasyuk v. Capital Management Services, LP, No. 18-1260 (2d Cir. 2019), the Second Circuit recently held that a debt collector’s letters informing a consumer of the total present amount of debt owed satisfies Fair Debt...more

NY’s Fourth Department Holds That Notice of Default Did Not Provide Clear and Unequivocal Notice to Accelerate the Debt

In Ditech Financial LLC v. Corbett, 2018 WL 6006682, at *1, —N.Y.S.3d —- (2d Dept. Nov. 16, 2018), the Appellate Division, Fourth Department, held that a notice of default sent to the borrowers-defendants, which discussed a...more

NY Appellate Court Holds Default Letter Stating Debt “Will Be Accelerated” Does Not Accelerate the Debt, De-Acceleration Must Be...

Mortgagees and their servicers should take note that a New York appellate court has confirmed that a default letter, stating the mortgage debt “will be accelerated” if the default is not cured, does not clearly and...more

Does the Word 'Will' Clearly Accelerate a NY Mortgage Debt?

Mortgage servicers and other financial institutions have been battling the issue of what affirmative act “clearly and unequivocally” accelerates a mortgage debt for years. Currently, there is a split in authority between the...more

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