The Consumer Financial Protection Bureau (CFPB or the Bureau) announced it would begin issuing Consumer Financial Protection Circulars (Circulars) to a “broad set of government agencies responsible for enforcing federal consumer financial law.” Director Rohit Chopra explained in a May 16, 2022, blog post that while the CFPB is the “principal regulator responsible for administering the federal consumer financial laws,” it is not the only agency tasked with enforcement. By issuing Circulars, the CFPB hopes to align enforcement across various regulators, ensuring consistency.

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Photo of Tonya Esposito Tonya Esposito

Tonya M. Esposito focuses her practice on a variety of consumer issues, including financial services, antitrust, and marketing and advertising. She has considerable experience representing clients in private litigation, as well as in government investigations brought by state attorneys general, the Federal Trade…

Tonya M. Esposito focuses her practice on a variety of consumer issues, including financial services, antitrust, and marketing and advertising. She has considerable experience representing clients in private litigation, as well as in government investigations brought by state attorneys general, the Federal Trade Commission (FTC), the U.S. Department of Justice (DOJ), the Food and Drug Administration (FDA), and the Consumer Financial Protection Bureau (CFPB).

With deep experience representing a variety of financial institutions in both litigation and compliance matters, Tonya represents clients in litigation involving claims brought under the Fair Credit Reporting Act (FCRA), the Fair Debt Collection Practices Act (FDCPA), the Real Estate Settlement Procedures Act (RESPA), the Truth in Lending Act (TILA), the Telephone Consumer Protection Act (TCPA), the state deceptive acts and practices laws (UDAAP), and many types of internal and government investigations. She regularly handles matters involving credit cards, student loans, residential and commercial mortgages, as well as privacy and FinTech issues.

Photo of Gil Rudolph Gil Rudolph

Gil Rudolph focuses his practice on the representation of finance companies, banks, mortgage originators and servicers, lease company transactions, retail installment transaction financers and other consumer financial service providers in regulatory and litigation matters. Gil also represents various alternative financial service providers, including…

Gil Rudolph focuses his practice on the representation of finance companies, banks, mortgage originators and servicers, lease company transactions, retail installment transaction financers and other consumer financial service providers in regulatory and litigation matters. Gil also represents various alternative financial service providers, including small dollar/short term lenders, check cashers, pawn and auto title lenders. He additionally represents various participants in the credit, debit, and prepaid card issuance and processing industries.

Photo of Benjamin M. Saul Benjamin M. Saul

Benjamin Saul is a shareholder in the firm’s Financial Regulatory and Compliance Practice. For two decades, Ben has handled high-stakes regulatory, enforcement, and litigation matters for corporate and individual clients in the consumer finance, specialty finance, fintech, and banking sectors.

Ben has helped

Benjamin Saul is a shareholder in the firm’s Financial Regulatory and Compliance Practice. For two decades, Ben has handled high-stakes regulatory, enforcement, and litigation matters for corporate and individual clients in the consumer finance, specialty finance, fintech, and banking sectors.

Ben has helped clients navigate dozens of contentious supervisory, enforcement, and litigation matters involving the Consumer Financial Protection Bureau (CFPB), and has been a leader in the private bar on CFPB matters since the Bureau’s inception in 2011. He also routinely assists clients in matters involving the FTC, DOJ, HUD, OCC, FRB, FDIC, state financial services authorities, state attorneys general, and state civil rights commissions. Ben’s enforcement matters have concerned fair lending and servicing, unfair deceptive and/or abusive trade practices, other federal and state consumer finance laws, AML/BSA, troubled or failed banks, fiduciary duties, financial institution fraud, supervisory ratings, and other safety and soundness issues.  These matters often have involved parallel proceedings by multiple enforcement agencies and/or private parties.

Ben also advises lenders, servicers, alternative financial service providers, and money service businesses on product and service development, licensing, compliance program enhancement, and the applicability of federal and state consumer credit and other financial services laws. He frequently helps clients understand how financial services law maps onto new technologies and innovative products, having worked on matters involving big data, artificial intelligence, marketplace and online lending, blockchain, digital assets and cryptocurrencies, digital banking, and payment systems.  In addition, Ben provides financial services regulatory support for corporate and capital markets transactions.

Jonathan Huie

Jonathan Huie has deep experience in the areas of government enforcement and regulatory matters across the technology, financial services, and food and drug industries. He advises businesses of all sizes on internal investigations and consumer issues. Jonathan works closely with clients on risk

Jonathan Huie has deep experience in the areas of government enforcement and regulatory matters across the technology, financial services, and food and drug industries. He advises businesses of all sizes on internal investigations and consumer issues. Jonathan works closely with clients on risk management issues with the goal of avoiding costly litigation and represents them in antitrust and complex commercial disputes when litigation cannot be avoided.