On 1/30/2020, the CFPB filed suit against Citizens Bank, N.A. (Providence, Rhode Island) based on allegations that the bank violated the Truth in Lending Act (TILA) and its implementing Regulation Z, including violations of amendments to TILA contained in the Fair Credit Billing Act and the Credit Card Accountability Responsibility and Disclosure Act.
In their complaint, the Bureau alleges that Citizens violated TILA and Regulation Z by failing to properly manage and respond to credit card disputes as Citizens allegedly automatically denied consumers’ billing error notices and claims of unauthorized use in certain circumstances. The complaint further alleges that Citizens failed to fully refund finance charges and fees when consumers asserted meritorious disputes or fraud claims, and failed to send consumers required acknowledgement letters and denial notices in response to billing error notices.
The Bureau further alleges that for several years Citizens violated TILA by violating provisions passed under the CARD Act. The Bureau alleges that Citizens violated TILA and Regulation Z by failing to provide credit counseling referrals to consumers who called Citizens’ toll-free number designated for that purpose. These alleged violations of TILA—including those under the FCBA and the CARD Act—and Regulation Z also constitute violations of the Consumer Financial Protection Act.
The CFPB complaint can be viewed here.