The FDCPA is a "strict liability statute" (Vangorden v Second Round, Ltd. Partnership, 897 F3d 433, 438 [2d Cir 2018]), and a debt collector's failure to give the FDCPA "mini-Miranda" warning in a communication made in connection with the collection of a debt is a per se violation of the statute unless the document in question constitutes "a formal pleading made in connection with a legal action." (See 15 USC § 1692e [11].) The reasons for the warning and the "formal pleading" exception were explained in Bohannon v LVNV Funding, LLC (2015 WL 893362, 2015 US Dist LEXIS 24976 [ED Va, Mar. 2, 2015, Civil No. 3:14-CV-354]):
"The FDCPA requires debt collectors to make certain disclosures on all communications 'in connection with the collection of any debt.' 15 U.S.C. § 1692e (11). Known as the 'mini-Miranda,' the warning tells the debtor that the creditor is trying to collect a debt and that the creditor can use information given by the debtor in the collection effort. This warning allows the unwary debtor to exercise caution in his communication with the creditor.