On January 30, 2020, the Bureau filed a lawsuit against Citizens Bank, N.A. (Citizens), alleging violations of the Truth and Lending Act (TILA) and its implementing Regulation Z, including TILA provisions passed under the Fair Credit Billing Act (FCBA) and Credit Card Accountability Responsibility and Disclosure Act (CARD Act), as well as violations of the Consumer Financial Protection Act of 2010 (CFPA) due to its violations of TILA and Regulation Z.