Regulatory changes
Advise some of the nation’s largest financial institutions in the legal and operational implementation of significant regulatory changes, including the Mortgage Servicing Rules in Regulations X and Z, the TILA-RESPA Integrated Disclosure Rule, and the Credit CARD Act.
General compliance
Advise clients on compliance matters related to various federal consumer financial laws, including the Truth in Lending Act (TILA), the Real Estate Settlement Procedures Act (RESPA), the Fair Credit Reporting Act (FCRA), the Electronic Fund Transfer Act (EFTA), the Homeowners Protection Act (HPA), the Equal Credit Opportunity Act (ECOA), the Fair Debt Collection Practices Act (FDCPA), and the Telephone Consumer Protection Act (TCPA).
Advise clients on how to best ensure compliance with complex state consumer protection statutes and related federal laws, including California’s Rosenthal Fair Debt Collections Practices Act and various states’ homeowners bills of rights.
Consumer Financial Protection Bureau (CFPB) examinations
Assist some of the nation’s largest financial institutions in preparing and managing CFPB examinations, including examinations on compliance management systems and various product lines. Assist mortgage servicers, mortgage originators, reverse mortgage servicers, credit card issuers, depository institutions and manufactured housing companies during their CFPB examinations. This work includes conducting risk assessments, responding to information requests, self-disclosing issues to the CFPB, working with examiners during on-site reviews, and responding to Proposed Action and Request for Response (PARR) letters and supervisory letters.
Consumer Financial Protection Bureau (CFPB) enforcement
Advise and assist multiple consumer financial service providers as they manage and respond to civil investigative demands (CIDs) issued by the CFPB. Assist clients with the development of compliance management systems and with the prevention of unfair, deceptive or abusive acts or practices (UDAAP).
Office of the Comptroller of the Currency (OCC)
Represented client in relation to OCC’s horizontal review of sales and incentive practices, which resulted in responding to supervisory letters and developing action plans.
Complaint responses
Managed a large bank’s escalated complaints response process by reviewing, revising, and drafting responses to complaints submitted through counsel, state attorneys general offices, state banking regulators, and federal regulators.