In Beach v. Ocwen Federal Bank, 523 U.S. 410 (1998), the Court addressed whether a borrower may assert his right to rescind as an affirmative defense in a collection action brought by the lender more than three years after the consummation of the transaction. Id. at 411-12. The borrowers in Beach acknowledged that their right to institute an independent proceeding for rescission under 15 U.S.C. 1635 lapsed three years after closing on the loan, but they argued that the restriction to three years in 1635(f) was a statute of limitation governing only the institution of the lawsuit, but had no effect when a borrower claimed the right of rescission as a defense. The Court rejected that view, and reasoned that Congress intended to foreclose the federal right to rescind provided under Truth in Lending Act (TILA), defensively or otherwise, after the three-year period has run. Id. at 419.