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Timothy A. Butler

Tim Butler helps companies thrive by developing tailored strategies to address their regulatory compliance challenges and vigorously defending them in government enforcement actions and bet-the-company lawsuits.

A former prosecuting attorney for the Federal Trade Commission (FTC) and former senior official in the Georgia Attorney General’s Office, Tim has led the defense of dozens of government investigations and enforcement actions brought by the FTC, the Consumer Financial Protection Bureau (CFPB), and the various state attorneys general. Tim also regularly defends clients in bet-the-company lawsuits, including complex business disputes and consumer class actions alleging privacy, false advertising, and unfair or deceptive business practice claims.

Tim is an experienced guide for companies struggling with regulatory complexity. He offers clear advice that helps his clients meet the demands of the ever-growing set of laws and regulations governing data privacy and cybersecurity, advertising and marketing practices, and consumer financial products and services. Clients rely on Tim’s business-minded and practical strategies to address their most difficult regulatory compliance challenges.

A graduate of the University of Chicago and Stanford Law School, Tim is a prolific author and regularly speaks to industry and trade groups about the evolving privacy landscape, about cutting-edge issues affecting payments and fintech companies, and about developments at the FTC, the CFPB, and within the state attorneys general community.

On Oct. 29, 2025, the Consumer Financial Protection Bureau (CFPB) withdrew its proposed rule that would have required certain nonbank financial companies subject to its supervisory jurisdiction to submit annual reports about their use of terms and conditions that attempt to waive or limit consumer rights and protections.
Continue Reading CFPB Withdraws ‘Fine Print’ Rule

Open banking frameworks are transforming how consumer financial data is shared and utilized, thanks to collaboration among financial institutions, technology companies, and regulators. With the CFPB revisiting the 2024 Final Rule under the Dodd-Frank Act, stakeholders are weighing in on the future of consumer data access and financial innovation.
Continue Reading CFPB Reopens Its Open Banking Rule for Comment

The Federal Trade Commission’s Rule on Unfair or Deceptive Fees, sometimes called the “Junk Fees Rule,” took effect on May 12, 2025. In advance of that effective date, the FTC published Frequently Asked Questions (FAQs) to provide guidance to consumers and businesses regarding the Rule.
Continue Reading FTC Issues FAQs on ‘Junk Fees’ Rule

On April 30, 2025, the Consumer Financial Protection Bureau (CFPB) announced that it “will not prioritize enforcement or supervision actions” related to obligations imposed by its Small Business Lending Rule (under Regulation B) against entities not covered by the Fifth Circuit Court of Appeals’ stay in Texas Bankers Association v. CFPB, No. 24-40705.
Continue Reading CFPB Will Not Enforce Small Business Lending Rule

On March 27, 2025, the Federal Trade Commission (FTC) filed a lawsuit and proposed settlement order resolving claims against Cleo AI, a fintech that operates a personal finance mobile banking application through which it offers consumers instant or same-day cash advances. The FTC alleges that Cleo deceived consumers about how much money they could get and how fast that money could be available, and that Cleo made it difficult for consumers to cancel its subscription service.
Continue Reading FTC Alleges Fintech Cleo AI Deceived Consumers

On Nov. 6, 2024, the Federal Trade Commission (FTC) released an administrative complaint and accepted a proposed consent order resolving claims against GGL Projects, Inc., an AI-enabled customer review platform

Continue Reading FTC Takes a Jab at AI-Enabled Sitejabber for Deceptive Consumer Reviews

On Nov. 18, 2024, the Federal Deposit Insurance Corporation (FDIC) announced a 45-day extension to the public comment period for its proposed rule making (Proposed Rule) that would establish new

Continue Reading FDIC Extends Comment Period for New Requirements for Custodial Accounts

On Nov. 12, 2024, the Consumer Financial Protection Bureau (CFPB) released a report examining federal and state privacy protections for consumers’ financial data. In the report, the CFPB “critiques” the

Continue Reading CFPB Urges States to Fill Gaps in Federal Financial Privacy Statutes