— including those in' this Circuit — have consistently recognized an implied private right of action under both. See, e.g., Zeffiro v. First Pa. Banking & Tr. Co., 623 F.2d 290 (3d Cir.1980); LNC Inv., Inc. v. First Fid. Bank, 935 F.Supp. 1333 (S.D.N.Y.1996) (citing cases); see also Bluebird Partners, L.P. v. First Fid. Bank, N.A., 85 F.3d 970, 974 (2d Cir.1996) (citing Zeffiro favorably, and describing it as “establishftng] a private cause of action under the [TIA]”); cf. In re Bankers Tr. Co., 450 F.3d 121, 126-27 (2d Cir.2006) (analyzing whether a trustee had complied with Section 315(b) without suggesting that there was no private right of action); Royal Park Investments SA/NV v. HSBC Bank USA, Nat. Ass’n, No. 14-CV-8175 (SAS), 2015 WL 3466121, at *14-15 (S.D.N.Y. June 1, 2015) (<HOLDING>): In Zeffiro, for example, the Third Circuit,
holding that the plaintiff stated a claim for tortious interference holding that the same reasoning regarding opinions that is used under sections 11 and 12 of the securities act of 1933 applies to claims under sections 10b and 20a of the 1934 act as these claims all share a material misstatement or omission element holding plaintiffs had stated a claim for intentional discrimination under the ada and  504 holding that the plaintiffs stated a claim under sections 315b and c of the tia holding that the plaintiffs stated a claim for conspiracy because they alleged an actionable tort