The Consumer Financial Protection Bureau’s creation placed many banks and nonbank financial services companies under broad federal supervision for the first time. Our nationally-recognized practice helps an array of institutions— including mortgage servicers and originators, credit bureaus, debt collection agencies, debt buyers, payday lenders, private student lenders, and auto finance companies—confront regulatory, supervisory and enforcement issues arising from this powerful new federal agency’s prolific activity.

Our consumer financial services team comprises regulatory lawyers and litigators who work together to assist clients in handling CFPB matters and scrutiny, including facilitating engagement with the CFPB to discuss rulemaking, preparing clients for CFPB exams, helping clients respond to CFPB civil investigative demands, and litigation when appropriate. Attorneys in our CFPB practice have decades of experience representing consumer financial services providers in dealing with government regulators.

Our experience in handling CFPB matters since the agency’s creation in 2010 has established us as a leader in this area of law. We monitor every CFPB action and keep clients informed with legal alerts and our award-winning blog, CFPB Monitor, which focuses exclusively on important CFPB developments.

REGULATORY/SUPERVISORY ASSISTANCE

We help clients plan for the impact of CFPB expectations. We assist clients in developing and assessing their compliance management systems, including policies and procedures, complaint handling, and internal audits. We conduct fair lending assessments for creditors in the mortgage, credit card, and auto industries. These assessments provide a statistical analysis of data to determine if any potential disparate impact exists. We also help clients identify and assess other areas of compliance risk, such as unfair, deceptive, or abusive acts or practices (UDAAP) and vendor management.

Our attorneys conduct a substantive review and assessment similar to a CFPB exam to prepare clients for every scenario they may face in an actual exam. We assist in responding to exam inquiries and organizing a presentation to the Bureau.

ENFORCEMENT/LITIGATION

Our litigators defend banks and nonbanks facing CFPB enforcement proceedings or enforcement actions brought by state attorneys general or regulators using UDAAP authority created by the Dodd-Frank Act.