U.S. Code » Title 15 » Chapter CHAPTER 41— CONSUMER CREDIT PROTECTION › Subchapter SUBCHAPTER II–A— CREDIT REPAIR ORGANIZATIONS

15 U.S.C. § 1679g

Civil liability

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(a) Liability establishedAny person who fails to comply with any provision of this subchapter with respect to any other person shall be liable to such person in an amount equal to the sum of the amounts determined under each of the following paragraphs:(1) Actual damagesThe greater of—(A) the amount of any actual damage sustained by such person as a result of such failure; or(B) any amount paid by the person to the credit repair organization.(2) Punitive damages(A) Individual actions

In the case of any action by an individual, such additional amount as the court may allow.

(B) Class actionsIn the case of a class action, the sum of—(i) the aggregate of the amount which the court may allow for each named plaintiff; and(ii) the aggregate of the amount which the court may allow for each other class member, without regard to any minimum individual recovery.(3) Attorneys’ fees

In the case of any successful action to enforce any liability under paragraph (1) or (2), the costs of the action, together with reasonable attorneys’ fees.

(b) Factors to be considered in awarding punitive damagesIn determining the amount of any liability of any credit repair organization under subsection (a)(2), the court shall consider, among other relevant factors—(1) the frequency and persistence of noncompliance by the credit repair organization;(2) the nature of the noncompliance;(3) the extent to which such noncompliance was intentional; and(4) in the case of any class action, the number of consumers adversely affected.(Pub. L. 90–321, title IV, § 409, as added Pub. L. 104–208, div. A, title II, § 2451, Sept. 30, 1996, 110 Stat. 3009–459.)Statutory Notes and Related SubsidiariesEffective Date

Section applicable after the end of the 6-month period beginning on Sept. 30, 1996, except with respect to contracts entered into by a credit repair organization before the end of such period, see section 413 of Pub. L. 90–321, as added by Pub. L. 104–208, set out as a note under section 1679 of this title.

Notes of Decisions
Cited in 40 cases (11 in the last 5 years), 1999–2026 · leading case: Laverne Jones v. Bernaldo Dancel, 792 F.3d 395 (4th Cir. 2015).
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Laverne Jones v. Bernaldo Dancel, 792 F.3d 395 (4th Cir. 2015). · cites it 7× “The arbitrator concluded, however, that the plaintiffs could recover for certain violations under CROA’s punitive damages provision, 15 U.S.C. § 1679g(a)(2). Noting, that defendants Amerix and Dancel did not observe CROA’s disclosure requirements when they “should have perceived…”
Hillis v. Equifax Consum. Servs., Inc., 237 F.R.D. 491 (N.D. Ga. 2006). · cites it 5× “§ 1679g(a)(l)(B) in an amount equal to all monies paid to Defendants for the Score Power services at issue (an amount that may exceed $200 million), as well as punitive damages pursuant to 15 U.S.C. § 1679g(a)(2)(B). E. Applicability of the CROA and Sequence of Motions…”
Kevin Ziober v. Blb Resources, Inc., 839 F.3d 814 (9th Cir. 2016). · cites it 2× “Despite the statute’s seeming contemplation of a judicial forum for claims, the Supreme Court rejected the argument that CROA created a procedural right to bring a lawsuit in court. As the Court reasoned, “[i]f the mere formulation of the cause of action in this standard fashion…”
Greenwood v. CompuCredit Corp., 615 F.3d 1204 (9th Cir. 2010). · cites it 4× “The "right to sue" listed in § 1679c(a) is provided for in 15 U.S.C. § 1679g, which establishes civil liability for violations of the CROA.”
Newton v. Am. Debt Servs., Inc., 854 F. Supp. 2d 712 (N.D. Cal. 2012). · cites it 3× “See 15 U.S.C. § 1679g(a)(3). The objectionable provisions obviously designed to apply to arbitration must be considered in evaluating the enforceability of the arbitration clause.”
In re Trans Union Corp. Privacy Litig., 211 F.R.D. 328 (N.D. Ill. 2002). · cites it 2× “The Credit Repair Organization’s Act ("CROA”), 15 U.S.C. § 1679g(a), and Equal Credit Opportunity Act ("ECOA”) 15 U.”
Nancy R. Murray, Plaintiff-Petitioner v. Gmac Mortg. Corp., Doing Bus. as ditech.com, Defendant-Respondent, 434 F.3d 948 (7th Cir. 2006). “15 U.S.C. § 1640 (a)(2)(B) (substituting “creditor” for “debt collector”).”
Gay v. CreditInform, 511 F.3d 369 (3rd Cir. 2007). “In contending that the statutes preclude arbitration of her claims, Gay points to 15 U.S.C. § 1679g, the CROA provision which prescribes the bases for determining civil liability and includes several references to a “court” and class actions in its discussion of punitive damages.”
Colorado Ex Rel. Salazar v. Jensen (In Re Jensen), 395 B.R. 472 (Bankr.D. Colo. 2008). · cites it 2× “See 15 U.S.C. § 1679g; Colo.Rev.Stat. § 12-14.”
Fed. Trade Comm'n v. Gill, 71 F. Supp. 2d 1030 (C.D. Cal. 1999). · cites it 2× “See 15 U.S.C. § 1679g. Section 409 provides that [a]ny person who fails to comply with any provision of this subchapter with respect to any other person shall be liable to such person in the amount equal to the sum of the amounts determined under each of the following…”
Zimmerman v. Puccio, 613 F.3d 60 (1st Cir. 2010). “” 15 U.S.C. § 1679g(a). The court’s $256.5 million award represented the amount paid by the class plaintiffs to the defendants through December 31, 2004.”
Picard v. Credit Solutions, Inc., 564 F.3d 1249 (11th Cir. 2009). “The “right to sue” referenced in the required disclosure is set forth separately in the civil liability section, 15 U.S.C. § 1679g(a), which does not mention the word “right,” the expression “right to sue,” or place any limitation on arbitration.”
Show all 40 citing cases →
— 15 U.S.C. § 1679g(a) — 12 cases
Nancy R. Murray, Plaintiff-Petitioner v. Gmac Mortg. Corp., Doing Bus. as ditech.com, Defendant-Respondent, 434 F.3d 948 (7th Cir. 2006). “15 U.S.C. § 1640 (a)(2)(B) (substituting “creditor” for “debt collector”).”
Zimmerman v. Puccio, 613 F.3d 60 (1st Cir. 2010). “” 15 U.S.C. § 1679g(a). The court’s $256.5 million award represented the amount paid by the class plaintiffs to the defendants through December 31, 2004.”
In re Trans Union Corp. Privacy Litig., 211 F.R.D. 328 (N.D. Ill. 2002). “The Credit Repair Organization’s Act ("CROA”), 15 U.S.C. § 1679g(a), and Equal Credit Opportunity Act ("ECOA”) 15 U.”
Picard v. Credit Solutions, Inc., 564 F.3d 1249 (11th Cir. 2009). “The “right to sue” referenced in the required disclosure is set forth separately in the civil liability section, 15 U.S.C. § 1679g(a), which does not mention the word “right,” the expression “right to sue,” or place any limitation on arbitration.”
Enriquez v. Countrywide Home Loans, FSB, 814 F. Supp. 2d 1042 (D. Haw. 2011).
— 15 U.S.C. § 1679g(a)(1) — 5 cases
Beech v. Litig. Practice Grp., PC (S.D. Miss. 2024).
Jackson v. Red Rock Credit Solutions, LLC (N.D. Cal. 2023).
Ensminger v. Credit Law Ctr., LLC (D. Kan. 2019).
Keith-amick (S.D. Ind. 2025).
Harris (W.D. Pa. 2025).
— 15 U.S.C. § 1679g(a)(2) — 2 cases
Laverne Jones v. Bernaldo Dancel, 792 F.3d 395 (4th Cir. 2015). “The arbitrator concluded, however, that the plaintiffs could recover for certain violations under CROA’s punitive damages provision, 15 U.S.C. § 1679g(a)(2). Noting, that defendants Amerix and Dancel did not observe CROA’s disclosure requirements when they “should have perceived…”
Willis v. Nationwide Debt Settlement Grp., 878 F. Supp. 2d 1208 (D. Or. 2012).
— 15 U.S.C. § 1679g(a)(2)(A) — 2 cases
Greenwood v. CompuCredit Corp., 615 F.3d 1204 (9th Cir. 2010). “The "right to sue" listed in § 1679c(a) is provided for in 15 U.S.C. § 1679g, which establishes civil liability for violations of the CROA.”
Harris (W.D. Pa. 2025).
— 15 U.S.C. § 1679g(a)(2)(B) — 2 cases
In re Trans Union Corp. Privacy Litig., 211 F.R.D. 328 (N.D. Ill. 2002). “The Credit Repair Organization’s Act ("CROA”), 15 U.S.C. § 1679g(a), and Equal Credit Opportunity Act ("ECOA”) 15 U.”
Hillis v. Equifax Consum. Servs., Inc., 237 F.R.D. 491 (N.D. Ga. 2006). “§ 1679g(a)(l)(B) in an amount equal to all monies paid to Defendants for the Score Power services at issue (an amount that may exceed $200 million), as well as punitive damages pursuant to 15 U.S.C. § 1679g(a)(2)(B). E. Applicability of the CROA and Sequence of Motions…”
— 15 U.S.C. § 1679g(a)(3) — 5 cases
Laverne Jones v. Bernaldo Dancel, 792 F.3d 395 (4th Cir. 2015). “The arbitrator concluded, however, that the plaintiffs could recover for certain violations under CROA’s punitive damages provision, 15 U.S.C. § 1679g(a)(2). Noting, that defendants Amerix and Dancel did not observe CROA’s disclosure requirements when they “should have perceived…”
Newton v. Am. Debt Servs., Inc., 854 F. Supp. 2d 712 (N.D. Cal. 2012). “See 15 U.S.C. § 1679g(a)(3). The objectionable provisions obviously designed to apply to arbitration must be considered in evaluating the enforceability of the arbitration clause.”
Colorado Ex Rel. Salazar v. Jensen (In Re Jensen), 395 B.R. 472 (Bankr.D. Colo. 2008). “See 15 U.S.C. § 1679g; Colo.Rev.Stat. § 12-14.”
Jackson v. Red Rock Credit Solutions, LLC (N.D. Cal. 2023).
Harris (W.D. Pa. 2025).
— 15 U.S.C. § 1679g(a)(l) — 2 cases
Hillis v. Equifax Consum. Servs., Inc., 237 F.R.D. 491 (N.D. Ga. 2006). “§ 1679g(a)(l)(B) in an amount equal to all monies paid to Defendants for the Score Power services at issue (an amount that may exceed $200 million), as well as punitive damages pursuant to 15 U.S.C. § 1679g(a)(2)(B). E. Applicability of the CROA and Sequence of Motions…”
Newton v. Am. Debt Servs., Inc., 854 F. Supp. 2d 712 (N.D. Cal. 2012). “See 15 U.S.C. § 1679g(a)(3). The objectionable provisions obviously designed to apply to arbitration must be considered in evaluating the enforceability of the arbitration clause.”
— 15 U.S.C. § 1679g(a)(l)(B) — 3 cases
Laverne Jones v. Bernaldo Dancel, 792 F.3d 395 (4th Cir. 2015). “The arbitrator concluded, however, that the plaintiffs could recover for certain violations under CROA’s punitive damages provision, 15 U.S.C. § 1679g(a)(2). Noting, that defendants Amerix and Dancel did not observe CROA’s disclosure requirements when they “should have perceived…”
Hillis v. Equifax Consum. Servs., Inc., 237 F.R.D. 491 (N.D. Ga. 2006). “§ 1679g(a)(l)(B) in an amount equal to all monies paid to Defendants for the Score Power services at issue (an amount that may exceed $200 million), as well as punitive damages pursuant to 15 U.S.C. § 1679g(a)(2)(B). E. Applicability of the CROA and Sequence of Motions…”
Lopez v. ML 3, LLC, 607 F. Supp. 2d 1310 (N.D. Fla. 2009).
— 15 U.S.C. § 1679g(b) — 2 cases
Hillis v. Equifax Consum. Servs., Inc., 237 F.R.D. 491 (N.D. Ga. 2006). “§ 1679g(a)(l)(B) in an amount equal to all monies paid to Defendants for the Score Power services at issue (an amount that may exceed $200 million), as well as punitive damages pursuant to 15 U.S.C. § 1679g(a)(2)(B). E. Applicability of the CROA and Sequence of Motions…”
Harris (W.D. Pa. 2025).
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