In U Alborzian v. JPMorgan Chase BankU, a California Appellate Court recently held that a lender may be liable under the Unfair Collection Practices laws for implying that a debt is still owed, when it is not. In UAlborzianU, Plaintiffs took out two loans to purchase a home in 2005. Both loans were secured by deeds of trust on their personal residence. Wells Fargo had the senior loan and Defendant JPMorgan Chase had the junior loan. Wells Fargo later foreclosed on the property, but the proceeds from the sale were not enough to pay off Chase’s loan. Chase later contacted the plaintiffs by letter, phone and through a collection agent attempting to collect the $60,000-$70,000 still due on the loan. Plaintiffs sued Chase and the collection agent, alleging that the Code of Civil Procedure extinguished Chase’s rights and therefore, the letters and calls were misleading and inappropriate. They claimed the misrepresentations violated the following statutes: 1) The Rosenthall Fair Debt Collection Practices Act; 2) Unfair Competition Law; 3) The Consumer Legal Remedies Act; and 4) The Fair Debt Collection Practices Act. The Court sustained the defendant’s demurrers without leave to amend. The Court of Appeals reversed, holding that the plaintiffs asserted viable causes of action and that the debt was not appropriate.