Overview
A.J. is special counsel in the Finance and Bankruptcy Practice Group in the firm's Washington, D.C. office.
Areas of Practice
A.J. has over a decade of experience helping banks, non-bank financial institutions, and other companies providing financial products and services in a wide range of matters including government enforcement actions, civil litigation, regulatory examinations, and internal investigations.
With a diversified regulatory, compliance, and enforcement background, A.J. counsels financial institutions in matters involving the Consumer Financial Protection Bureau (CFPB) since it was first established, having served as counsel in numerous investigations, enforcement actions, and supervisory matters. Beyond his CFPB work, A.J. frequently represents institutions in matters initiated by many other federal agencies, including the Department of Justice (DOJ), Federal Trade Commission (FTC), and the Federal Deposit Insurance Corporation (FDIC), as well as state Attorneys General and other state regulators such as the New York Department of Financial Services (NYDFS) and Department of Financial Protection and Innovation (DFPI).
A.J.’s extensive enforcement and bank and consumer regulatory experience, in particular with consumer protection statutes, includes focus on the Truth in Lending Act (TILA), the Real Estate Settlement Procedures Act (RESPA), the Equal Credit Opportunity Act (ECOA), the Fair Housing Act (FHAct), the Fair Credit Reporting Act (FCRA), the Fair Debt Collection Practices Act (FDCPA), the Servicemembers Civil Relief Act (SCRA), Telephone Consumer Protection Act (TCPA), and various unfair, deceptive, or abusive acts and practices (UDAAP) laws under the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act), Section 5 of the FTC Act, and various state laws.
A.J. is active in the District of Columbia Bar, where he serves on the Board of Governors. He is a past president of the Washington D.C. chapter of the South Asian Bar Association of North America (SABA) and has been recognized as a Rising Star by SABA.
Experience
Experience
- Represented indirect auto finance company in a DOJ and state AG investigation into subprime auto loan origination and securitization practices
- Represented several card issuers in CFPB enforcement actions relating to unfair billing tactics and deceptive marketing with respect to credit card add-on products
- Represented a large student loan servicer in parallel federal government investigations, focusing on issues related to UDAAP and SCRA compliance
- Represented a credit reporting bureau in a CFPB enforcement action alleging UDAAP violations relating to the marketing of credit scores to consumers
- Represent financial institutions in connection with data breach and cyber matters, including in connection with related state regulatory and enforcement investigations into breaches
- Represent multiple companies stemming from a CFPB sweep of investigations, which led to enforcement actions and negotiated settlements, alleging violations of the CFPA prohibition against deceptive acts and practices, the MAP Rule, and Regulation Z
- Representation of multiple mortgage companies in FCA and FIRREA investigations by the DOJ, various U.S. attorneys’ offices, HUD, and VA, concerning compliance with the Fair Housing
Administration (FHA) Direct Endorsement Lender program guidelines, VA loan requirements, HECMs, and Fannie Mae and Freddie Mac origination and servicing guidelines - Represented several banks and non-banks through CFPB examinations and pre-enforcement matters and responding to Proposed Action and Request for Response (PARR)
- Represented a non-bank in a confidential bank regulator enforcement matter based on a referral from the CFPB to the DOJ for alleged fair lending violations
- Responded to FDIC investigation subpoena on behalf of a national bank alleging RESPA violations arising out of co-marketing agreements and desk rentals
- Defended residential mortgage lender in FCA qui tam litigation in Southern District of California regarding the FHA government-insured loan program
- Representing large financial institution in connection with CFPB supervisory examination into fair lending activities
- Advised multiple non-banks on issues related to their advertising and marketing practices in compliance with TCPA, TILA, the MAP Rule, and UDAP/UDAAP
- Advised a FinTech payments processor on matters related to disclosure delivery, advertising and marketing compliance, and risk management
- Represented major card issuer in identifying, self-reporting to CFPB, and remediating UDAAP non-compliance, resulting in the avoidance of a consent order and civil money penalties
- Helped a card issuer redesign existing rewards program, create benchmarks against best in class standards, conduct risk assessments, integrate grandfathered balances, and terminate legacy programs
- Advised credit, debit, and prepaid card issuers in compliance management, deferred interest, and technical compliance with consumer financial laws and regulations
- Participated on due diligence teams to assess regulatory risks related to the acquisition of financial services entities, including mortgage originators and servicers
- Representation of a bank in connection with an FDIC examination that alleged RESPA violations
Honors
Honors
Community Leader Award, South Asian Bar Association of Washington, D.C. (SABA-DC), 2021
Rising Star, South Asian Bar Association of North America (SABA), 2017
Insights
Articles
- Co-author, The Supreme Court’s Ruling in Seila Law LLC v. CFPB: The End of CFPB Constitutionality Litigation? The Business Lawyer (Spring 2021)
- Co-author, The devil is in the details: LabMD imposes limitations on the FTC’s enforcement authority, Cybersecurity Law Report (June 2018)
- Co-author, The FCC’s Expanding Definition of Privacy, Journal of Internet Law (October 2015)
- Co-author, Petitions To Modify or Set Aside CFPB Civil Investigative Demands: Analysis of Recent Decisions, LexisNexis® Emerging Issues Analysis (January 2013)
Consumer Finance and Fintech Blog Posts
- "Banking Agencies Provide Crypto-Asset Roadmap as a Result of Interagency “Policy Sprints”," November 24, 2021
- "Eleventh Circuit orders en banc rehearing in Hunstein," November 19, 2021
- "New York Enacts Consumer Credit Fairness Act, Impacting Debt Collection Actions," November 17, 2021
- "OCC: Modernize the Bank Regulatory Perimeter on Bank-Fintech Partnerships," November 17, 2021
- "Banking Agencies: Mortgage Servicers Should Prepare For Increased Scrutiny," November 12, 2021
- "New Commissioner Appointed to lead CA DFPI: Cloey Hewlett," November 12, 2021
- "OCC Calls for Regulation of Crypto Banking," November 9, 2021
- "NMLS Transition for California Financing Law Licensees: December 31, 2021 Deadline," November 9, 2021
- "President’s Working Group Releases Report on Stablecoins," November 5, 2021
- "FTC to Increase Enforcement Against “Dark Patterns” Directed at Consumers," November 3, 2021
- "FTC Finalizes Safeguard Rules for Non-Bank Financial Institutions," November 3, 2021
- "CFPB Director Chopra Appears at First House Hearing Since Approval as Director," November 1, 2021
- "CFPB, DOJ and OCC Take Action Against National Bank for Alleged Redlining," October 25, 2021
- "CFPB to Tech Companies: Submit Payment System Information," October 25, 2021
- "First CFPB Enforcement Action Under New Director: $6 Million Fine Against Prison Financial Services Company," October 25, 2021
- "NYDFS Issues Proposed Rules to Implement New Commercial Financing Disclosure Law," October 25, 2021
- "Hawaii Amends Small Dollar Lending Law," October 21, 2021
- "NMLS Transition for California Financing Law Licensees: December 31, 2021 Deadline," October 21, 2021
- "CFPB Updates Supervision and Examination Manual, Adds IT Examination," October 21, 2021
- "CFPB Opts Not to Take Action Against Banking App," October 13, 2021
- "OCC: Crypto and DeFi Must Avoid Another Financial Crisis," October 4, 2021
- "Chopra Confirmed as CFPB Director," October 1, 2021
- "More Regulatory Clarity on the Horizon for FinTech," September 30, 2021
- "Court Agrees with FTC: Can Seek Relief under Section 19," September 27, 2021
- "CFPB Alleges that Service Provider Helped Credit-Repair Businesses Charge Illegal Fees," September 22, 2021
- "CFPB Sues Online Lender for Alleged Violations 2016 Consent Order," September 21, 2021
- "Money Transmission Licenses Required for Virtual Currency Activities in Arkansas and Florida," September 21, 2021
- "Wyoming and Maine Issue New Licensing Requirements Potentially Impacting Passive Loan Investors," September 21, 2021
- "Are Income Share Agreements Loans? The CFPB Says Yes," September 10, 2021
- "FTC Approves Changes to FCRA Rules; Clarifies Application to Motor Vehicle Dealers," September 9, 2021
- "CFPB Issues Proposed Rule Under Section 1071 of Dodd-Frank to Collect Small Business Lending Data," September 3, 2021
- "Banking Agencies Release Due Diligence Guidance on Community Bank-FinTech Relationships," August 31, 2021
- "FFIEC Issues Updated Guidance on Authentication and Access to Financial Institution Services and Systems," August 26, 2021
- "CFPB To Issue Data Collection Regulations for Small Business Lenders in September," August 13, 2021
- "CFPB Confirms November 30 Effective Date for Debt Collection Final Rules," August 11, 2021
- "California Regulator Signals New Scrutiny of Student Lending Industry, Enters Into Consent Order with Servicer of Income Share Agreements," August 10, 2021
- "Maine Enacts “True Lender” Legislation, Amends Consumer Credit Code to Include Anti-Evasion Provisions," August 9, 2021
- "CFPB Reaches Correct Resolution On Juneteenth Disclosure Issues," August 9, 2021
Finance and Bankruptcy Law Blog Posts
- "Federal Agencies Request Comments on Risk Management Guidance for Third-Party Relationships," July 19, 2021
- "CFPB Takes Action Against FinTech Company for Originating Unauthorized Loans," July 19, 2021
- "FHFA Releases Policy Statement On Fair Lending," July 15, 2021
- "CFPB Blogs About Buy Now Pay Later," July 13, 2021
- "FDIC Chairman Discusses FinTech and Bank Innovation," July 7, 2021
- "CFPB and Georgia AG Settle With Debt-Relief Company," July 7, 2021
- "DFS Settles with Indirect Auto Lenders to Resolve Fair Lending Violations," July 7, 2021
- "CFPB Issues Summer 2020 Supervisory Highlights," July 7, 2021
- "House Votes to Repeal OCC True Lender Rule," June 28, 2021
- "Lina Khan Sworn in as New FTC Chair," June 28, 2021
- "CFPB to Resume Examinations Under the Military Lending Act," June 22, 2021
- "FTC Takes Novel Approach to Seek Civil Money Penalties in the Wake of AMG Capital Ruling," June 18, 2021
- "Second Circuit Reverses Ruling in FDCPA Case," June 15, 2021
- "House Subcommittee Launches Investigation into FinTech Companies’ Role in Allegedly Fraudulent PPP Loans," June 15, 2021
- "CFPB Issues Mortgage Servicing FAQs," June 15, 2021
- "CFPB Issues FAQs on Electronic Fund Transfers," June 8, 2021
Privacy Law Blog Posts
- "Non-Banking Institutions Will Want to Review Security Measures in Light of Update to Safeguards Rule," November 4, 2021
- "European Securities Watchdog Fine Highlights Importance of Data Integrity and Regulatory Access," September 27, 2021
- "NYDFS Issues Ransomware Guidance," July 12, 2021
Media Mentions
Memberships
Memberships
American Bar Association, Banking Law Committee
District of Columbia Bar Association, Board of Governors (2018-2021)
National Asian Pacific American Bar Association
South Asian Bar Association of North America
South Asian Bar Association of Washington, DC
Practices
Industries
Education
- LL.M., The George Washington University Law School, 2008
- J.D., Western New England University School of Law, 2007
- B.A., Simon Fraser University, 2001
Admissions
- District of Columbia
- Maryland