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Strubel v. Comenity Bank


This case presents the question of a private plaintiff’s standing under the Truth in Lending Act to bring an action for statutory damages for the alleged failure of a creditor to provide the account-opening disclosures required under 15 U.S.C. § 1637(a)(7) and its implementing regulation. The Bureau filed an amicus brief arguing that 15 U.S.C. § 1640(a) authorizes private plaintiffs to seek statutory damages for violations of these disclosure obligations. The brief also argues that a violation of regulations issued under TILA can give rise to statutory damages to the same extent as a violation of TILA would.

Full brief

Strubel v. Comenity Bank