Illinois Case Update - First District Clarifies Acceleration Letter Ambiguities for Lenders

In CitiMortgage, Inc. v. Hoeft, 2015 IL App (1st) 150459 (1st Dist. Aug. 17, 2015), the Illinois' Appellate Court clarified an issue occasionally raised by borrowers attacking the sufficiency of acceleration letters sent out by lenders—that acceleration letters identifying both the amount required to cure a default and mentioning additional charges that might accrue (like regularly scheduled payments and late charges) creates ambiguity as to the amount required to cure the default.