District Court Holds 1099-C Language Not in Violation of FDCPA or ICAA

The Northern District of Illinois recently granted summary judgment in favor of the defendant, a debt collector, in a case challenging the following Form 1099-C language contained in a debt settlement letter:

IRS requires certain amounts that are discharged as a result of the cancellation of debt to be reported on a Form 1099-C.  You will receive a copy of the Form 1099-C if one is required to be filed with the IRS.

See Moses v. LTD Financial Services I, Inc. et al., N.D. Illinois Case No. 16-cv-5190 (August 9, 2017).  (The court’s Memorandum and Order can be found here.)

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