What is the statute of limitations for a plaintiff to bring a claim under Section 1635 of the Bankruptcy and Insolvency Act?

Plaintiff does not allege the date her loan closed, although she strongly hints that she brought suit more than three years after the date of the loan. Normally, plaintiff need not allege that her lawsuit is timely, since the statute of limitations is an affirmative defense. However, Section 1635(f) is not technically a statute of limitations, rather it is a statute of repose. As such, "section 1635(f) completely extinguishes the right of rescission at the end of the 3 year period." Beach, 523 U.S. at 412. As a result, the expiration of the 3-year period "depriv[es] the courts of subject matter jurisdiction when a 1635 claim is brought outside the three-year limitation period." Miguel v. Country Funding Corp., 309 F.3d 1161, 1164 (9th Cir. 2002) (as amended December 23, 2002).