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Our nationwide team represents a wide variety of entities in the banking, insurance, lending, and payments industries that provide B2B and consumer services, including payment processors, third-party integrators, data analytics providers, online marketers, payment gateways, technology solution providers, resellers, and other traditional and emerging financial products companies.

  • Counseled clients on developing and taking to market various financial products, including short-term small-dollar consumer credit products offered to account holders; on various obligations relative to third-party vendors; and on various consumer-related issues under the Dodd-Frank Wall Street Reform and Consumer Protection Act, the Truth in Lending Act, the Electronic Funds Transfer Act, and state law counterparts.
  • Advised a banking client on the development and eventual rollout of a short-term, small-dollar consumer lending product. Our work included an in-depth analysis of the potentially applicable state and federal laws, and drafting the products’ terms and conditions.
  • Advised a banking client on a dispute with a third-party service provider of an early mortgage payment processing product. The bank sought to move the product in-house, and we were able to achieve a favorable settlement with the third-party service provider, which had a long-term contract with the bank. Our advice also included compliance with relevant state and federal consumer laws.
  • Served for more than 10 years as corporate and compliance counsel to a global payment card network, handling internal investigations, compliance gap analyses, and audit-related reviews in operating divisions in Europe, Asia, Africa, and the United States. Matters have involved export control compliance for the hardware, software, and technology in the company’s core payment systems global business, trade sanctions, anti-money laundering, anticorruption, securities- and accounting-related issues, and employee fraud.
  • Served as longtime outside privacy and data security counsel to a large regional financial services entity that includes a collection of banks, providing incident response advice, developing privacy policies, and addressing affiliate data-sharing compliance issues as well as mobile payment concerns.
  • Advised a multibrand consumer financial services company on compliance with myriad privacy and security laws and regulations applicable to its online personal finance platform and related websites and Internet applications, including cross-site marketing initiatives.
  • Advised a financial services organization on privacy issues arising in connection with a major corporate reorganization.
  • Represented multiple financial institutions, including banks and entities in the automobile industry, in managing compliance obligations under the Gramm-Leach-Bliley Act. Our work included developing appropriate notice and opt-out forms and procedures as required by the Privacy Rule, crafting information security policies and standards to comply with the Safeguards Rule, implementing vendor due diligence and oversight procedures, and negotiating privacy- and security-oriented contract provisions.
  • Represented multiple financial services clients, advising on their information-sharing practices with law enforcement and participation in groups such as the Financial Services Information Sharing and Analysis Center (FS-ISAC).
  • Represented merchants, data analytics providers, and mobile payments solutions providers in response to information requests and civil investigative demands by the Federal Trade Commission.
  • Advised client on proposed integration of blockchain processes into existing infrastructure and operations associated with origination, fulfillment, settlement, and mortgage servicing in support of client information governance and records and information management services.
  • Advised a digital currency platform services provider in response to a multimillion-dollar cyber theft of bitcoin from a digital currency exchange.
  • Advised a gold-backed digital currency system in its launch.

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