The Massachusetts Consumer Protection Act (Gen. Law Ch. 93A) affords consumers – including residential borrowers – a private right of action to seek injunctive relief and damages caused by unfair or deceptive acts and practices. A lender or servicer liable under Chapter 93A is exposed to actual damages caused by the unfair or deceptive act or practice, mandatory double or treble damages if a court finds the act or practice was knowing or willful, and mandatory recovery of attorneys’ fees and costs regardless of the amount of damages actually caused (even if the act or practice was not knowing or willful).

Most times, a residential borrower must send a 30-day demand letter to the lender/servicer before filing a lawsuit that contains a Chapter 93A claim. The demand letter must identify the claimant and reasonably describe the unfair or deceptive act or practice and the injury suffered, as well as demand relief. A recipient of a demand letter has the opportunity to respond within 30 calendar days of the mailing or delivery of the letter. The demand letter, and the 30-day response period, is a jurisdictional prerequisite to filing suit in most cases involving residential borrowers and other consumers. The goal of this demand-response process is to educate the parties and foster a reasoned settlement if at all possible.

The Importance of a Thorough Investigation

A lender/servicer receiving a Chapter 93A demand letter has an affirmative duty to investigate the facts and consider legal precedent to determine whether or not to make a written tender of settlement in response to the demand letter. A thorough investigation and reasoned response cannot be overstated. That is because, beyond potentially being the impetus for a pre-litigation settlement, Chapter 93A ties an improper response to additional liability and a proper response to potentially significant limitations of liability.

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Photo of David G. Thomas David G. Thomas

David advises on individual and corporate disputes during the entire dispute-resolution life cycle, including through strategic negotiation, mediation, other forms of alternative dispute resolution, and adjudication through trial when needed or required. David has experience with many subject matters, including unfair or deceptive…

David advises on individual and corporate disputes during the entire dispute-resolution life cycle, including through strategic negotiation, mediation, other forms of alternative dispute resolution, and adjudication through trial when needed or required. David has experience with many subject matters, including unfair or deceptive business practices disputes in individual and putative class action settings, including under Massachusetts General Laws Chapter 93A—the Massachusetts Consumer Protection Act. Boston magazine selected David as a “Top Lawyer—Class Action” in 2022 and 2023. Also, David works with clients on avoiding disputes proactively by identifying and ameliorating existing or potential dispute risks in business policies and practices.

Photo of James P. Ponsetto James P. Ponsetto

James P. Ponsetto is a trial attorney with broad experience involving complex business and bankruptcy-related litigation. Jim has served as counsel for corporations and individuals in federal and state courts, before arbitration panels, and in connection with mediation proceedings. He litigates various types

James P. Ponsetto is a trial attorney with broad experience involving complex business and bankruptcy-related litigation. Jim has served as counsel for corporations and individuals in federal and state courts, before arbitration panels, and in connection with mediation proceedings. He litigates various types of civil disputes, including breach of contract claims, securities claims, class action suits, consumer protection claims, intellectual property matters, lender liability claims (including Truth-in-Lending disputes and claims arising in connection with residential foreclosures), construction disputes, employment disputes (management side), tax disputes, title insurance disputes and related matters. His bankruptcy litigation experience involves adversary proceedings and contested matters concerning multiple areas, including fraudulent conveyance actions (including preference actions), claim disputes, motions to dismiss Chapter 11 proceedings, and confirmation disputes.