Washington, D.C.
Clients turn to Noah when developing new products and services across payments, consumer and business lending, real estate and PropTech, cryptocurrency and digital assets and artificial intelligence. He often engages in the early stages of product planning and development, when businesses have the greatest flexibility to address legal and regulatory considerations without limiting innovation. Working in both English and Spanish, Noah also has a particular focus on helping foreign companies enter the U.S. market and advising businesses on the consumer financial, privacy and regulatory considerations that accompany new products and services.
Across his practice, Noah counsels clients on the full spectrum of consumer financial product design, payments, privacy and artificial intelligence. He brings a business-focused approach to applying established legal frameworks to rapidly evolving technologies, helping clients identify regulatory risk, evaluate available options and develop practical paths forward.
Previously, Noah served as Senior Counsel in the Legal Division of the Consumer Financial Protection Bureau (CFPB), where he worked directly with the agency’s general counsel on complex and emerging issues in consumer finance. He advised divisions across the CFPB on supervision, rulemaking and enforcement activities and spearheaded the Bureau’s work on data privacy, including the intersection of the federal Gramm-Leach-Bliley Act (GLBA) and state privacy laws. Noah also advised on the scope of the CFPB’s authority, unfair, deceptive and abusive acts and practices (UDAAP) and the more than 20 federal consumer financial laws administered by the Bureau.
Areas of Focus
- Product Design and Market Entry. Bringing new products to market by identifying where consumer financial law, privacy law and AI governance will constrain a design and presenting options that center business choice, purpose and values.
- Artificial Intelligence and Responsible Innovation. Advising regulated entities how to harness the potential of AI while observing their regulatory obligations, including model governance, explainability, fair lending exposure and the documentation a supervisory exam will expect to review.
- Consumer Financial Data and Privacy. Advising businesses on how to leverage customer data – including data monetization, data sharing arrangements and vendor structures – while respecting privacy law and user expectations at the intersection of the GLBA and state privacy law.
- Federal Consumer Financial Law and UDAAP. Advising on federal consumer protection laws – including the GLBA, RESPA, EFTA, FCRA, TILA and ECOA – and on the UDAAP doctrines he applied while at the CFPB.
- Government Investigations, Supervision and Enforcement. Defending companies and individuals in government investigations, supervisory exams, enforcement and cross-border investigations to minimize disruption and protect the business’s reputation.
- Transactional Support for Regulated Entities. Supporting deal teams on transactions involving regulated entities, to satisfy regulatory requirements, address consumer financial law and data diligence and streamline change-in-control government approvals.