Strubel v. Comenity Bank
This case presents the question of a consumer’s standing to bring an action for statutory damages under the Truth in Lending Act (TILA) 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 a supplemental amicus brief arguing that the consumer had standing under Article III of the U.S. Constitution to bring this case. Specifically, the Bureau’s brief argues that a consumer who does not receive the disclosures required under TILA has suffered a concrete harm sufficient to support Article III standing.