In Wike v. Vertrue, Inc., 566 F.3d 590 (6th Cir. 2009), the Sixth Circuit became the first court of appeals to determine when the statute of limitations starts to run for alleged violations of the Electronic Funds Transfer Act (15 U.S.C. § 1693). Under § 1693m(g), claims alleging violations of the EFTA must be filed “within one year from the date of the occurrence of the violation.” The statute does not specify, however, whether the clock starts running when the defendant arranges for a transfer that would violate the Act, or the later date on which the transfer of funds actually occurs. The Sixth Circuit concluded that the limitations period does not start to run until funds are transferred. The court did not address the related question of whether the discovery rule might toll the running of the limitations period.