Jeremy T. Rosenblum

Jeremy T. Rosenblum leads the firm's Consumer Financial Services Group. He has practiced law for 32 years and devoted the past 27 years primarily to consumer financial services and financial institutions law.

Mr. Rosenblum's practice focuses on federal and state lending and consumer practices laws, with emphasis on the interplay between federal and state laws. He regularly provides guidance, both directly to clients and to colleagues handling litigation matters, on the scope of preemption of federal usury laws (e.g., Section 85 of the National Banking Act, Title V of the Depository Institutions Deregulation and Monetary Control Act of 1980); federal banking laws (e.g., Section 24 (Seventh) of the National Banking Act and the Home Owners' Loan Act and implementing regulations); and consumer protection laws such as the federal Real Estate Settlement Procedures Act (RESPA), the Truth in Lending Act (TILA), the Fair Credit Reporting Act, the Equal Credit Opportunity Act, the Electronic Funds Transfer Act, and state "UDAP" statutes prohibiting unfair and deceptive acts and practices.

In addition to his consumer lending and consumer litigation practice, Mr. Rosenblum represents banks, thrifts, and other entities in charter transactions; mergers, acquisitions, and conversions; the introduction of new products; geographic expansion; asset securitizations; purchases of loan servicing rights; and public offerings and private placements of equity and debt instruments.

Mr. Rosenblum's practice involves regular dealings with industry trade groups and regulators. In this regard, he has drafted a number of amicus curiae briefs, to the Supreme Court and other courts, on behalf of a number of industry and business trade groups, including the American Bankers Association, the Consumer Bankers Association, the U.S. Chamber of Commerce, the Mortgage Bankers Association, and the American Financial Services Association.

Representative Matters

• Obtained for Huntington National Bank in 1998 a letter from the OCC concluding that national banks with offices in multiple states are permitted to charge the interest allowed by the laws of their home states upon compliance with minimal requirement [OCC Interp. Letter No. 822 (Feb. 17, 1998) (sometimes colloquially known as the "Rosenblum Letter")]; letter reversed OCC policy that, until that point, had required a highly fact-intensive analysis that hampered the ability of multistate banks to export home state interest charges
• Served as counsel in Greenwood Trust Company v. Massachusetts, the first decision in the nation holding that federally insured financial institutions may charge and export as "interest" not only periodic rates of interest but also flat late charges
• Served as counsel in Hudson v. ACE Cash Express, where the Southern District of Indiana applied Section 85 to dismiss with prejudice usury allegations against ACE, a nonbank, holding that a national bank's utilization of ACE's services in originating and servicing its loans and its sale to ACE of a 90- to 95-percent participation interest in the loans did not justify treating ACE as the "true" lender
• Served as counsel in Murray v. Cross Country Bank, the first case in the nation holding that, when Congress enacted the "FACT Act" amendments to the Fair Credit Reporting Act (FCRA), it explicitly prohibited private FCRA lawsuits against users of consumer reports and instead provided that only government authorities could enforce the relevant FCRA requirements

Professional Activities

American Bar Association
Section of Business Law, Consumer Financial Services Committee; past Co-Chair, Committee's Preemption and Federalism Subcommittee (previously known as Sub-Committee on Federal Preemption, Conflict of Laws, and Usury); past Vice Chair, Committee's Interstate Delivery of Financial Services Subcommittee; and past Vice Chair, Committee's Long-Range Planning Subcommittee

American College of Consumer Financial Services Lawyers, Fellow

Conference on Consumer Finance Law, Governing Committee

Consumer Financial Services Law Report, Financial Services Advisor

Recognition & Accomplishments

Chambers USA: America's Leading Lawyers for Business, banking and finance: financial services regulation: consumer finance (compliance), national ranking; and banking and finance: mainly regulatory (Pennsylvania band one), 2008-2013

The Best Lawyers in America, banking and finance law, 2008-2013

Community Activities

Tutor, Philadelphia Reads elementary-school tutoring program

Board Memberships

Middle East Forum, a think tank that seeks to define and promote American interests in the Middle East

Yale Law School (J.D. 1979)

Stanford University (A.B 1975, with honors)
Member, Phi Beta Kappa

Pennsylvania

Illinois