Government Investigations, Examinations and Enforcement

Lawyers in Hudson Cook, LLP’s Government Investigations, Examinations and Enforcement practice area provide support to consumer financial services companies and others facing government scrutiny. These lawyers have, in total, decades of experience as private practitioners, in-house counsel, and counsel for federal agencies – including the Consumer Financial Protection Bureau (CFPB) and the Federal Trade Commission (FTC).

Investigations

Since 2012, we have represented clients in more than 100 government investigations. Our experience in consumer financial services regulation and our familiarity with state and federal regulatory agencies help us work towards efficient resolution of government actions. Representative engagements include:

Enforcement

Enforcement actions arise when a supervisory or investigative matter cannot be resolved informally. We usher clients through the enforcement process, working with them through settlement negotiations, litigation and appeals, and otherwise advocating for their interests. Representative engagements include:

  • Defending CFPB district court litigation against an auto finance company relating to military lending practices
  • Defending a mortgage company in CFPB litigation to enforce a Civil Investigative Demand
  • Defending auto title companies in CFPB administrative adjudications
  • Negotiation of settlement agreements with the CFPB, FTC, DOJ and state agencies

Examinations

Examinations involve an extended process that demands careful preparation, quick responses and effective remedial action. We assist clients in preparing for exams by evaluating the organization’s Compliance Management System. During exams, we help clients navigate the process with an eye toward resolving issues through the supervisory process. When regulators identify violations, we advocate for non-public resolutions through responses to CFPB PARR Letters or similar agency notices. Representative engagements include:

  • Drafting CFPB PARR responses for auto finance companies, small dollar lenders, and others, in some cases resulting in no public action and the elimination of supervisory findings
  • Assisting banks and service providers in preparing for and responding to OCC, Federal Reserve Board, FDIC and state prudential regulators’ exams
  • Assisting clients in preparing for and navigating CFPB exams
  • Crafting remediation plans and corrective actions
Other Practice Areas
Attorneys Practicing in this Area
INSIGHTS

Attorneys Practicing in this Area

March 01, 2015

Don’t Fence Me In

Thomas B. Hudson

Partner Emeritus

December 01, 2015

Congressional Staff Report Reveals Sad Inner Workings of CFPB Fair Lending Attack on Dealer Compensation

L. Jean Noonan

Partner

April 01, 2015

Spacemen Abduct Regulators!

Thomas B. Hudson

Partner Emeritus

December 15, 2015

Can California Lenders Pay Referral Fees to Unlicensed Brokers?

Robert A. Cook

Partner Emeritus

May 01, 2015

Seismic Shift

Nicole F. Munro

Partner

January 01, 2016

Looking Ahead

Eric L. Johnson

Partner

September 01, 2015

Lots of Pages, But a Single Document

January 28, 2016

Asset Purchase or Consumer Loan: One State High Court Weighs In

Catherine M. "Cathy" Brennan

Partner

December 01, 2015

Here Come the “Readability” Police

Nicole F. Munro

Partner

February 17, 2016

The Commonwealth Decision

Catherine M. "Cathy" Brennan

Partner