Truth in Lending: 11.7.6.2.2 Statutory damages for untimely disclosures
The Sixth934 and Ninth Circuits935 have interpreted section 1640(a) as overriding what would seem implicit in the disclosure requirements—that to be made properly, they must be made in time to be effective. As a result, these courts find that statutory damages are not available for violations of TILA’s timing requirement.