Taylor v. MRS BPO, LLC, 2:17-cv-01733

Plaintiff Christine M. Taylor received a March 29, 2016 collection letter from MRS BPO, LLC regarding a $5,635.52 Chase consumer credit‑card debt.
The letter was on MRS letterhead, identified MRS as a debt collector, and contained boxed text: “RE: CHASE BANK USA N.A.” plus an MRS account number and the last four digits of a “CLIENT ACCT#.”
The body instructs the debtor to reference the “CHASE BANK *2 USA N.A. Option Letter” when calling and warns that Chase may offer less favorable terms if the debt is settled for less than the full balance.
Taylor sued under the FDCPA, alleging the letter failed to identify the current owner/creditor of the debt and thus violated 15 U.S.C. § 1692e(10).
Defendant moved to dismiss, arguing (1) §1692e does not require creditor identification in subsequent communications, (2) the letter adequately disclosed Chase as creditor, and (3) any misstatement was immaterial.
The court concluded the letter, read as a whole under the least‑sophisticated‑consumer standard, adequately disclosed Chase as the creditor and granted dismissal with prejudice.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a debt collector must identify the current creditor in a communication not alleged to be the §1692g initial notice	Taylor contends the letter is susceptible to a reading that does not identify the current owner, violating §1692e(10)	MRS argues §1692e does not impose a creditor‑identification requirement for subsequent communications and that plaintiff effectively seeks §1692g protections in all communications	Court assumed without deciding that §1692e claim could proceed but resolved the case on disclosure adequacy and dismissed the claim
Whether the March 29, 2016 letter sufficiently disclosed the creditor to the least sophisticated consumer	Taylor said the letter’s use of “RE:” and “client” could reasonably be read as leaving the creditor unclear or implying a different unidentified entity	MRS pointed to multiple explicit references to Chase (subject line, option‑letter reference, warning about Chase products) and to clear identification of MRS as the collector	Court held the letter, read as a whole, made it clear Chase was the current creditor; no reasonable but inaccurate interpretation justified liability, so dismissal was granted

Greco v. Trauner, Cohen & Thomas, L.L.P., 412 F.3d 360 (2d Cir.) (least‑sophisticated consumer standard explained)
Clomon v. Jackson, 988 F.2d 1314 (2d Cir.) (origin of least‑sophisticated‑consumer test)
Russell v. Equifax A.R.S., 74 F.3d 30 (2d Cir.) (description of the least‑sophisticated consumer)
McStay v. I.C. Sys., Inc., 308 F.3d 188 (2d Cir.) (debt‑collection letters should be analyzed as a whole)
Dewees v. Legal Serv., LLC, 506 F. Supp. 2d 128 (E.D.N.Y.) (assess whether least‑sophisticated consumer would be aware a creditor name appears)
Emanuel v. Am. Credit Exch., 870 F.2d 805 (2d Cir.) (no requirement that a collection letter quote statutory language verbatim)