Pete Z. Siaway v. Webster Bank, N.A.

Summary

The United States District Court for the District of Rhode Island granted Webster Bank, N.A.’s motion to dismiss Pete Z. Siaway’s Second Amended Complaint with prejudice. The court held that the Equal Credit Opportunity Act claim lacked factual allegations of discrimination, the Truth in Lending Act claim was untimely, the E-SIGN and UETA claims lacked a private right of action, and the Rhode Island Deceptive Trade Practices Act claim was barred by the statutory exemption for regulated entities. The court also denied further leave to amend.

Holdings

1. The Second Amended Complaint failed to state a plausible claim under 15 U.S.C. § 1691(a) because it alleged neither facts showing discrimination based on a protected characteristic nor facts showing that similarly situated applicants outside the protected class received more favorable treatment.
2. The TILA damages claim was time-barred because the alleged disclosure violations occurred at the August 2023 loan closing and the action was not filed until September 2025.
3. The E-SIGN and UETA claims failed as a matter of law because neither statute provides a private right of action, and the plaintiff did not allege that he electronically signed the relevant documents.
4. The DTPA claim failed as a matter of law because the Bank is a regulated entity and the challenged lending conduct falls within the statutory exemption for actions or transactions permitted under laws administered by state or federal regulatory bodies.
5. The Court declined to grant further leave to amend because the request was contingent on dismissal, such requests are disfavored in the First Circuit, and the plaintiff had already received leave to amend after the Court identified deficiencies in the original complaint.

Questions Presented

1. Whether the Second Amended Complaint plausibly alleged discrimination under the Equal Credit Opportunity Act.
2. Whether the Truth in Lending Act damages claim was barred by the one-year statute of limitations.
3. Whether the Electronic Signatures in Global and National Commerce Act and the Rhode Island Uniform Electronic Transactions Act provide a private right of action or were plausibly invoked by the allegations.
4. Whether the Rhode Island Deceptive Trade Practices Act applies to conduct by a regulated lending institution.
5. Whether the plaintiff should receive further leave to amend after the Court had previously allowed amendment and identified pleading deficiencies.

Disposition

dismissed