Consumer Regulatory

Representative Experience

  • Advised a publicly traded corporation regarding the potential jurisdiction of the Consumer Financial Protection Bureau over the operations of multiple subsidiaries. Work included assessments of whether subsidiaries were “covered persons”, whether subsidiaries may be considered to be “larger participants” subject to CFPB supervision, and authority the CFPB may exercise over the company and its subsidiaries under consumer protection statutes for which full or partial authority was transferred to the CFPB.