Recently, the United States Court of Appeals for the Second Circuit vacated the dismissal of a complaint alleging a violation of 15 U.S.C. ยง 1692e when a debt collector that notified consumers of their account balance failed to disclose that the balance may increase due to interest and costs. Avila v. Riexinger, 2016 WL 1104776 (2d Cir. March 22, 2016). The Second Circuit oversees Connecticut, New York, and Vermont
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