The Northern District of Illinois struck down the idea that the safe harbor language provided in Miller v. McCalla somehow creates new disclosure requirements for debt collectors. In Jasmine Chatman v. Alltran Education, Inc., 2018 WL 741465 (N.D. Ill. Feb. 7, 2018), the court dismissed a claim arguing this notion. The court found that including a balance due at the time of the letter and a simple statement saying interest is accruing, directing the consumer to the original loan agreement for the accrual rate, is sufficient to put the consumer on notice of the amount owed.
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