The Second Appellate District affirmed a judgment. The court held that Congress intended that all private actions alleging violations of the federal be Truth in Savings Act be barred and, accordingly, no private action was permissible against a bank under the California unfair-competition law to redress alleged violations of a disclosure provision in the Truth in Savings Act.
Harold Rose and others (collectively, Rose) maintained deposit accounts at Bank of America, N.A. (B. of A.). B. of A. informed Rose on his written account statement that there were “upcoming pricing changes” as detailed in an “enclosed brochure.” Subsequently, B. of A. deducted higher monthly fees from Rose’s account.
