American Bankers Association Regulatory Compliance Conference

Speaking Engagement | June.21.2022 - June.24.2022

Orlando, FL

Understanding the ESG Impact on Compliance
Tuesday, June 21, 2022 - 10:00 AM EDT

Environmental and social governance continues to evolve, even as state legislatures are proposing or passing bills prohibiting the use of ESG factors in making lending decisions, forcing compliance officers to better understand their roles and responsibilities. Jeff Naimon discussed the impact of ESG on lending and overall compliance governance, especially as it relates to safety and soundness.

What Regulators are Watching in a Disrupted Consumer Financial Services Market
Thursday, June 23, 2022 - 7:30 AM EDT

Former regulators from the Consumer Financial Protection Bureau and the Maryland Office of the Commissioner of Financial Regulation discussed federal and state efforts to regulate the consumer financial services market in a period of both swift innovation and an increased focus on equity and fairness.

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Speakers

Jeffrey Naimon Partner, Financial & Fintech Advisory, Strategic Advisory & Government Enforcement (SAGE)

Washington, D.C.

See my bio

D:+1 202 349 8030
E: [email protected]

Practice:

Financial & Fintech Advisory
Strategic Advisory & Government Enforcement (SAGE)
Fintech

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Jeffrey Naimon Partner

Washington, D.C.

He defends financial services companies facing complex examination or enforcement matters before the Consumer Financial Protection Bureau (CFPB), the Federal Trade Commission (FTC), and federal and state banking regulators, with a focus on fair lending, unfair, deceptive or abusive acts and practices (UDAAP), loan servicing, privacy and credit reporting, debt collection, servicemember protections and other consumer protection issues.

He assists banks and nonbanks (including fintech entities) structure, negotiate and operate a variety of partnerships, outsourcing programs and other third-party arrangements, including performing due diligence, negotiating transactions and advising on ongoing oversight protocols to meet regulatory expectations for third-party arrangements.

Jeff also assists in negotiating acquisition, capital markets and servicing transactions, advising on how best to structure the transaction to reduce risk and expedite deal closure, performing due diligence and assisting in obtaining the necessary change of control and other regulatory approvals.

Jeff is consistently recognized as a leading lawyer in Financial Services Regulation: Consumer Finance (Compliance) in Chambers USA, which praised him for his "extremely high intellect regarding compliance matters and negotiation skills. There's none better at arguing a disputed point." He is also a Fellow of the American College of Consumer Financial Services Lawyers.

He currently serves as the Co-chair of the Professional Development Task Force and previously served as Co-chair (2011-2013) and Co-vice Chair (2008-2010) of the Truth in Lending Subcommittee of the American Bar Association’s Consumer Financial Services Committee and has authored numerous articles on consumer financial services.

Prior to joining Orrick, Jeff was a partner at Buckley LLP.

John Coleman Partner, Financial & Fintech Advisory, Strategic Advisory & Government Enforcement (SAGE)

Washington, D.C.

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D:+1 202 349 8006
E: [email protected]

Practice:

Financial & Fintech Advisory
Strategic Advisory & Government Enforcement (SAGE)
Fintech

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John Coleman Partner

Washington, D.C.

Prior to joining Orrick, John was a partner at Buckley LLP, which he joined after 15 years in federal government service as a litigator and advisor to senior policymakers, most recently as Deputy General Counsel for Litigation and Oversight at the Consumer Financial Protection Bureau. He joined the CFPB soon after its creation in 2010 and was one of a core group of attorneys tasked with interpreting the authorities granted to the agency by the Consumer Financial Protection Act of 2010 and establishing the procedures by which the agency exercises those authorities. He was the first person to appear in court on behalf of the CFPB and was involved in every significant litigation matter in the agency’s history prior to his departure. As Deputy General Counsel, he managed the team of attorneys responsible for representing the Bureau in litigation, including appellate matters, and before congressional oversight bodies.

John served every director or acting director in the CFPB's history during his tenure at the CFPB, advising them and senior officials in the Division of Supervision, Enforcement, and Fair Lending on a range of complex legal and policy matters, including those arising in the course of examinations, investigations and enforcement actions. He also advised the Director and senior officials in the Division of Research, Markets, and Regulations with respect to rulemakings, and represented the agency in all rulemaking challenges.

Prior to joining the CFPB, John was a trial attorney in the Federal Programs Branch of the Department of Justice’s Civil Division, representing federal agencies and officials in high-profile civil litigation, including cases brought under the U.S. Constitution, the Administrative Procedure Act and federal antidiscrimination laws.

Following law school, he served as a law clerk for the Honorable T.S. Ellis III, of the United States District Court for the Eastern District of Virginia.

Jedd Bellman Senior Counsel, Financial & Fintech Advisory, Strategic Advisory & Government Enforcement (SAGE)

Washington, D.C.

See my bio

D:+1 202 349 8043
E: [email protected]

Practice:

Financial & Fintech Advisory
Strategic Advisory & Government Enforcement (SAGE)
Fintech
Government Investigations and Enforcement Actions
Higher Education and Student Loan Financing
Internal Investigations
State Legislative & Regulatory Practice
State Attorneys General Investigations & Enforcement

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Jedd Bellman Senior Counsel

Washington, D.C.

Jedd was the Assistant Commissioner for Non-Depository Supervision in the Office of the Maryland Commissioner of Financial Regulation, where he coordinated the licensing and supervision of approximately 23,000 individuals and business entities covering the mortgage, student loan, consumer finance, sales finance, debt services, credit reporting and money services industries. He also managed the office’s regulatory investigations and enforcement actions, including playing a leadership role in every significant multistate enforcement matter handled by state regulators during his tenure. Additionally, Jedd oversaw numerous successful legislative and regulatory initiatives.

Prior to that, Jedd served as Counsel and Senior Policy Advisor at the U.S. House of Representatives, where he developed policy and legislative agendas in the areas of housing and financial services, small business and minority business.

Jedd also served as Assistant Attorney General for Maryland, where he handled mortgage fraud and payday lending enforcement prosecutions, as well as mortgage compliance, payday lending and money services business investigations.

In 2022, Jedd was recognized by the American Association of Residential Mortgage Regulators with its Distinguished Service Award. Following law school, he served as law clerk to Judge John K. Olson of the U.S. Bankruptcy Court, Southern District of Florida.

Prior to joining Orrick, Jedd was Senior Counsel at Buckley LLP.

Caroline Stapleton Partner, Financial & Fintech Advisory, Strategic Advisory & Government Enforcement (SAGE)

Washington, D.C.

See my bio

D:+1 202 461 2904
E: [email protected]

Practice:

Financial & Fintech Advisory
Strategic Advisory & Government Enforcement (SAGE)
Fintech

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Caroline Stapleton Partner

Washington, D.C.

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.

Keisha Whitehall Wolfe Counsel, Financial & Fintech Advisory, Strategic Advisory & Government Enforcement (SAGE)

Washington, D.C.

See my bio

D:+1 202 349 8046
E: [email protected]

Practice:

Financial & Fintech Advisory
Strategic Advisory & Government Enforcement (SAGE)
Fintech

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Keisha Whitehall Wolfe Counsel

Washington, D.C.

Her practice includes advising clients on:

Federal and state compliance requirements, including Secure and Fair Enforcement (SAFE Act) and Fair Debt Collection Practices Act (FDCPA) compliance
Licensing and regulation of residential and commercial mortgage lenders, brokers and servicers; consumer lenders; installment lenders; debt collectors; and payment processors, financial technology companies, money transmitters and other money services businesses (MSB)
Origination and mortgage servicing rights-related state and federal laws and regulations; state mortgage loan originator work from home guidance; MSB-related activities; and advertising and collection practices
Regulatory compliance, state examination and enforcement matters, and the Nationwide Multistate Licensing System & Registry (NMLS) functionality

Prior to joining Orrick, Keisha was counsel at Buckley LLP. She previously served as acting deputy commissioner at the State of Maryland Office of the Commissioner of Financial Regulation.