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Financial Services Law Insights and Observations

CFPB Files Briefs in Three TILA Actions

CFPB TILA

Lending

On April 13, the CFPB filed amicus briefs in TILA cases pending in the ThirdFourth, and Eighth Circuits. As it did previously in a brief filed in the Tenth Circuit, the CPFB argued that borrowers who do not receive the material disclosures required by TILA are not required to file suit within the three-year rescission period. Rather, the CFPB argues that a borrower can rescind the transaction as long as they provide notice to the lender of the cancellation within three years of consummation.