Iowa Code » Chapter 537 — CONSUMER CREDIT CODE
Iowa Code

Iowa Code § 537.5114 (2026)

Complaint — proof

✓ current as of July 2026
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1. In an action brought by a creditor against a consumer arising from a consumer credit transaction, the complaint shall allege the facts of the consumer’s default, the amount to which the creditor is entitled, and an indication of how that amount was determined.

2. No default judgment shall be entered in the action in favor of the creditor unless the complaint is verified by the creditor, or unless sworn testimony, by affidavit or otherwise, is adduced showing that the creditor is entitled to the relief demanded. [C75, 77, 79, 81, §537.5114] \n 537.5115 Reserved.\n\nTue Dec 09 22:02:53 2025 Iowa Code 2026, Chapter 537 (58, 3) §537.5201, CONSUMER CREDIT CODE 54\n\n PART 2 CONSUMERS’ REMEDIES \n

Notes of Decisions
Cited in 8 cases (1 in the last 5 years), 1978–2022 · leading case: Capital One Bank (USA), N.A. v. Denboer, 791 N.W.2d 264 (Iowa Ct. App. 2010).
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Capital One Bank (USA), N.A. v. Denboer, 791 N.W.2d 264 (Iowa Ct. App. 2010). · cites it 90× “It only requires “an indication of how [the amount claimed by the creditor] was determined,” see Iowa Code § 537.5114 (1), “the minimum amount of information necessary to compute the award,” see UCCC 5-114 cmt.”
ITT Fin. Servs. v. Zimmerman, 464 N.W.2d 486 (Iowa Ct. App. 1990). · cites it 20× “The Zimmermans’ contention has merit if section 537.5114 contains statutory procedures necessary to invoke the authority of the court to hear and determine a case.”
IPALCO Employees Credit Union v. Culver, 309 N.W.2d 484 (Iowa 1981). · cites it 4× “5111, The Code, nor did its petition indicate how the amount in default was determined as required by section 537.5114, The Code. Answering, Culvers relied on chapter 537 defenses, estoppel, and the statute of limitations.”
Lloyd's Plan, Inc. v. Brown, 268 N.W.2d 192 (Iowa 1978). “Defendant contends plaintiff’s petition did not conform with § 537.5114(1), The Code, which specifies what a creditor’s petition must contain.”
Cavalry SPV I, LLC v. Kenneth W. Brown (Iowa Ct. App. 2022). · cites it 4× “2d at 278 (quoting Iowa Code § 537.5114 (1)). In any event, Cavalry’s authorized agent attested that “at no time prior to the commencement of this action did [Brown] communicate to [Cavalry], either orally or in writing, of any unresolved dispute with the account.”
Bank of Am., N.A. v. John Salerno (Iowa Ct. App. 2018). · cites it 2× “2 The petition included the proof required under Iowa Code section 537.5114 (2017) for a credit card company to bring a complaint against a consumer to recover a debt.”
Robert Clauss v. Laidlaw & Co. UK Ltd. (Iowa Ct. App. 2019). · cites it 2× “1990) (noting that the applicable law in the case, section 537.5114, was binding in small claims cases).”
Citibank, N.A. v. Kevin D. Surber (Iowa Ct. App. 2015). · cites it 2× “Iowa Code § 537.5114 (1); see also Denboer, 791 N.”
— Iowa Code § 537.5114(1) — 3 cases
ITT Fin. Servs. v. Zimmerman, 464 N.W.2d 486 (Iowa Ct. App. 1990). “The Zimmermans’ contention has merit if section 537.5114 contains statutory procedures necessary to invoke the authority of the court to hear and determine a case.”
Capital One Bank (USA), N.A. v. Denboer, 791 N.W.2d 264 (Iowa Ct. App. 2010). “It only requires “an indication of how [the amount claimed by the creditor] was determined,” see Iowa Code § 537.5114 (1), “the minimum amount of information necessary to compute the award,” see UCCC 5-114 cmt.”
Lloyd's Plan, Inc. v. Brown, 268 N.W.2d 192 (Iowa 1978). “Defendant contends plaintiff’s petition did not conform with § 537.5114(1), The Code, which specifies what a creditor’s petition must contain.”
— Iowa Code § 537.5114(2) — 2 cases
Capital One Bank (USA), N.A. v. Denboer, 791 N.W.2d 264 (Iowa Ct. App. 2010). “It only requires “an indication of how [the amount claimed by the creditor] was determined,” see Iowa Code § 537.5114 (1), “the minimum amount of information necessary to compute the award,” see UCCC 5-114 cmt.”
ITT Fin. Servs. v. Zimmerman, 464 N.W.2d 486 (Iowa Ct. App. 1990). “The Zimmermans’ contention has merit if section 537.5114 contains statutory procedures necessary to invoke the authority of the court to hear and determine a case.”
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