Just cite the Federal Statutue as a separate cause of action. Here is an example.
(TRUTH IN LENDING ACT, 15 U.S.C. § 1601 et seq. )
1. Plaintiffs repeat, re-allege and incorporate by reference the foregoing paragraphs.
2. Defendants failed and refused to give notice of their alleged assignment of the Deed of Trust to Plaintiffs. Defendants have transferred title of their real property to the Defendants.
3. Defendants violated the TILA and Regulation Z § 226.18 which require a creditor to disclose among other things, Annual Percentage Rate calculated using the methods prescribed in the Regulation Z, the amount financed, and the total finance charge.
4. Defendants violated the TILA and Regulation Z § 226.23 which require a creditor to give the notice of right of rescission to the consumer.
5. Defendants may have violated other provisions of TILA. This allegation will be supplemented after discovery.
6. Defendants may have violated other statutes and regulations. This allegation will be supplemented after discovery.
7. Had Defendants made the full disclosure as required by TILA, Plaintiffs would not have entered into the unconscionable financing arrangement.
8. Had Defendants made the full disclosure as required by TILA, Plaintiffs would have made other available arrangements such as financial assistance from relatives and/or sale of his house to stop the foreclosure process.
9. Plaintiffs have been harmed and suffered actual damages proximately caused by the conduct of Defendants.
WHEREFORE, Plaintiffs request that judgment be entered against Defendants as follows:
A. Judgment canceling or rescinding the contract and restoring the parties to the status quo ante;
B. Plaintiffs be awarded actual damages suffered as a result of Defendants’ conduct;
C. Judgment for Plaintiffs’ attorneys’ fees and costs;
D. Interest on the judgment rendered herein at the maximum lawful rate from the date of its rendition until paid in full; and
E. Such other and further relief as this Court deems just and proper.