Caroline Stapleton


Washington, D.C.

Caroline Stapleton advises financial institutions in federal and state regulatory compliance, supervision and enforcement matters.

Client-centered experiences are at the heart of Caroline’s practice. She has provided a wide variety of institutions, from fintech startups to multinational banks, with tailored, practical guidance that considers each company’s unique characteristics and strategic goals. Caroline draws on her prior experiences as an attorney at a federal prudential regulator and as the head of compliance at a consumer finance company to give clients a comprehensive picture of the legal risks and opportunities each new matter presents.

Her work on behalf of financial services providers has included:

  • Providing guidance regarding novel or complex regulatory questions, often in the context of developing new financial products and services
  • Performing compliance risk assessments of marketing, underwriting, pricing, origination, servicing and loss mitigation activities
  • Advising banks and supervised lenders with examinations by federal and state regulators, including responding to exam findings, CAMELS ratings, Matters Requiring Attention (MRA/MRIA) and enforcement referrals
  • Strategically responding to and defending enforcement actions by state and federal regulators, including the Consumer Financial Protection Bureau (CFPB), Office of the Comptroller of the Currency (OCC), Federal Deposit Insurance Corporation (FDIC), Federal Reserve Board and Department of Justice (DOJ), and, if necessary, negotiating favorable settlements
  • Developing strategies for bank partnership, state licensing and bank charter opportunities for consumer financial services providers
  • Conducting internal investigations of suspected misconduct or violations of an institution’s policies and/or regulatory requirements

In these and other representations, Caroline brings strong substantive knowledge of the key federal and state statutes and regulations governing the financial services industry. Her specific areas of focus include:

  • Fair lending and anti-discrimination laws, including the Fair Housing Act (FHA) and the Equal Credit Opportunity Act (ECOA)
  • Prohibitions on unfair, deceptive or abusive acts or practices (UDAP and UDAAP)
  • Technical regulatory compliance under federal and state laws governing loan marketing, disclosures, settlement practices, servicing and collection practices, consumer reporting and electronic payments
  • Federal preemption, including under the National Bank Act
  • Compliance management best practices and regulatory expectations, including third-party vendor and merchant oversight
  • Treatment and disclosure of confidential supervisory information (CSI)
  • State lease-to-own laws and regulations

Prior to joining Orrick, Caroline was senior counsel at Buckley LLP. She also has served as an attorney-advisor in the litigation division of the OCC, where she represented the agency in civil litigation, bank receivership preparation, employment disputes and other administrative contexts. Caroline also gained valuable in-house experience as the head of compliance and assistant general counsel of a Richmond-based consumer finance company.