Transamerica Mortgage Advisors, Inc. v. Lewis (TAMA)

·1979

What the Court Decided

The Court unanimously held that the word 'void' in Section 215 of the Investment Advisers Act carried customary incidents of voidness that implied a private right of action for rescission, though it declined to imply a damages remedy under Section 206.

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Cited In

FS Credit Opportunities Corp. v. Saba Capital Master Fund

2025 Term · 24-345

Central to the entire case — TAMA found an implied private right of action for rescission under Section 215 of the IAA based on the word 'void,' and the dispute centers on whether the 1980 ICA amendments preserved or eliminated that same right.