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- Defended large financial institution in sales practices investigation (of demand deposit accounts, credit cards, lines of credit, and online bill pay) by CFPB and OCC and involving DOJ relating to allegations of violations of UDAAP, TILA, TISA, and EFTA, resulting in client avoiding a public enforcement action to enforce compliance with a Civil Investigative Demand, which we convinced the CFPB was unnecessary.
- Defended national data aggregator in FCRA investigation by CFPB, resulting in client receiving closing letter indicating Bureau decision to not refer to a public enforcement action.
- Defended client in and resolved with no fine a CFPB investigation relating to enforcement of UDAAP, FDCPA, TILA regarding rent-to-own products.
- Defended client in CFPB investigation relating to enforcement of FDCPA and UDAAP regarding debt-collection practices on behalf of two large credit card issuers.
- Defended large financial institution in CFPB investigation relating to bank’s role in payment processing for various online lender customers of the bank, resulting in client avoiding a public enforcement action for liability based on processor status in payday lending context.
- Advised and counseled financial institution in CFPB investigation relating to deposit reconciliation practices and alleged UDAAP practices.
- Advised and counseled major student loan servicer client (top 4) in investigation by CFPB and involving Department of Education and DOJ, resulting in client avoiding a public enforcement action.
- Defended cruise company client in CFPB investigation into EFTA, UDAAP, and payroll cards, resulting in client avoiding a public enforcement action.
Represented parent company of early payday loan business entities in litigation, resulting in decision by CFPB to drop charges against our client (lawsuit decision made by CFPB prior to my being involved). - Advocated for two credit card issuers before the CFPB in ex parte rulemaking proceedings regarding the arbitration rule.
- Advocated for consumer credit industry company in matters involving financial inclusion and ECOA before the CFPB in rulemaking proposals and public policy (and also before Congress).
- Advocated for global trade association in matter before the CFPB in regards to Section 1031 data collection regulation (including preparing comment letter).
- Provided product counseling and compliance advice to various clients in the context of CFPB supervision, inquiries, or oversight matters, including on products such as: mortgage, escrow accounts, flood insurance, income-share agreements, buy-now/pay-later, data enrichment and aggregator services, student loan services for online coding bootcamps, and cloud services (financial privacy) issues.
While at CFPB:
- Served as first-chair for multiple federal investigations and obtained sworn testimony from corporate witnesses or whistleblowers in 15 investigational hearings and documentary evidence through dozens of civil investigative demands that I prepared.
- Build-out of Field Litigation Team and implemented federal policy priorities at CFPB’s inception.
- Helped establish procedures used by CFPB Enforcement in connection with investigatory matters; drafted consent order templates and protocols for investigational hearings; undertook special projects concerning establishing the agency standard for “related person” liability for executives and directors, indirect liability through service providers, protocols for joint investigations with federal agencies; and helped set precedents for CFPB protocols for deciding charges, obtaining injunctive relief and consumer restitution, and imposing civil money penalties.
- Investigated banks and financial services companies’ compliance with TILA, EFTA, RESPA, UDAAP, SCRA, Telemarketing Sales Rule, and “assisting and facilitating” liability rules, and to execute new rules regarding civil money penalty fund, investigational hearings and demands, and protocol for filing suits in federal district court.
- Led multi-agency investigation matters involving CFPB, DOJ, FTC, and state attorneys general, on payment processor investigations through a novel SQL code investigative method that I crafted utilizing big datasets.
Note: matters include Ms. Lee's work at prior firms before she founded Tessellate Law.
