written request it “would be liable for any resulting damages including any denial of credit because of the reporting of such charges as delinquent to credit reporting agencies.”); Hutchinson v. Delaware Savings Bank FSB, 410 F.Supp.2d 374 (D.N.J. 2006) (recognizing that denial of credit because of negative reporting to credit reporting agencies could constitute actual damages under RESPA). b. Non-pecuniary Damages There is some disagreement on whether RESPA provides for the recovery of non-pecuniary injuries such as emotional distress under “actual damages.” See In re Tomasevic, 273 B.R. 682, 687 (Bankr.M.D.Fla.2002) (finding that actual damages under section 2605 were limited to economic pecuniary injury); Ploog v. HomeSide Lending, Inc., 209 F.Supp.2d 863, 870 (N.D.Ill.2002) (<HOLDING>); Johnstone v. Bank of America, N.A., 173
holding in a fcra case that plaintiffs may not rely on mere  conclusory statements  rather they must  sufficiently articulate  true demonstrable emotional distress  including the factual context in which the emotional distress arose evidence corroborating the testimony of the plaintiff the nexus between the conduct of the defendant and the emotional distress the degree of such mental distress mitigating circumstances if any physical injuries suffered due to the emotional distress medical attention resulting from the emotional duress psychiatric or psychological treatment and the loss of income if any holding that actual damages under respa included emotional damages holding that respas actual damages provision allows for the recovery of emotional distress holding that emotional distress damages are not recoverable under section 504 holding that a tort claim for intentional infliction of emotional distress is distinct from a claim for emotional distress damages under the employment discrimination statute