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MoForecast: State AGs and Consumer Financial Protection: Anticipating Shifts in Enforcement Focus

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As the Consumer Financial Protection Bureau (CFPB) faces uncertainty, state attorneys general (state AGs) are poised to fill the...

MoForecast: State AGs and Consumer Financial Protection: Anticipating Shifts in Enforcement Focus

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Carrie H. Cohen is global co-chair of the Investigations + White Collar Defense practice group and the firm’s State + Local Government Enforcement team. Prior to joining the firm, Carrie served in the New York State Attorney General’s Office as Chief of the Public Integrity Bureau and an Assistant Attorney General in the Civil Rights Bureau where she received the Louis J. Lefkowitz Memorial Award for outstanding service. Carrie also served as an Assistant U.S. Attorney in the Southern District of New York (SDNY) where she prosecuted public corruption and securities matters, including obtaining the first trial conviction of former Speaker of the New York State Assembly Sheldon Silver.As a former state and federal prosecutor, Carrie routinely represents corporations, boards, and c-suite executives in government-facing investigative and regulatory matters with a particular focus on state and local government matters. Carrie’s extensive trial experience and distinguished record of success in high‑stakes, white collar defense matters cement her position as a leading lawyer who often is called upon as trial counsel for particularly sensitive matters. Carrie’s trial and white collar expertise have been recognized by a variety of organizations including Chambers USA, which describes her as “. . . a terrific trial lawyer with great judgment and timing, [who] knows how to present complex cases in a digestible way.” Carrie also routinely prepares clients who are called to testify before Congress and state and city legislatures and works on matters that involve multijurisdictional investigations and significant media attention. Carrie is a recognized industry expert in public corruption and state and local government actions. Carrie frequently is selected by government agencies to serve as independent counsel and issue public reports, which has included her appointment as Independent Monitor for the Federal Deposit Insurance Corporation, Special Counsel to the New York City Council, Special Independent Counsel to the City of Rochester, and Counsel to the California Attorney General’s Office (CA AG) as well as being part of the Monitorship Team appointed by DOJ for the global Odebrecht corruption matter. She also was appointed by Governor Kathy Hochul to the Metropolitan Transit Authority Inspector General’s Board and serves as its Acting Chair as well as having been appointed by the Chief Judge of the United States District Court for the Eastern District of New York as Counsel to the Court’s Grievance Committee. Carrie also is an Adjunct Professor at the University of Pennsylvania Law School, where she teaches a seminar on Public Corruption and the Law. Carrie serves on multiple bar committees and task forces as part of her effort to promote the rule of law. She was appointed Chair of the New York State Bar Association’s (NYSBA) Task Force on Domestic Terrorism and Hate Crimes and served as a member of the NYSBA Task Force on Wrongful Convictions. As a leader of the Bar, Carrie serves as a Vice President and Trustee of the Federal Bar Council and President of its Inn of Court and was appointed Co-Chair of the Federal-State Judicial Advisory Council as well as prior service as a Vice President of the New York City Bar, Chair of its Executive Committee, and member of its Nominating Committee. Carrie also is a member of the Board of Directors of Volunteers of Legal Service, an organization that provides pro bono legal services to the New York community, and was appointed by the SDNY to its Criminal Justice Act Panel to serve as counsel to indigent defendants in federal criminal cases. Carrie has long been dedicated to advancing women in the legal profession, both in the United States and globally. She co-chairs Morrison Foerster’s Women’s Strategy Committee, a group that works with firm leaders to ensure the advancement of women remains a strategic priority, and serves as a member of the New York City Bar’s Cyrus R. Vance Center for International Justice, where she spearheads a professional development program for women lawyers in Latin America and South Africa. She is also a member of the Women’s Forum of New York and the Belizean Grove, both of which are by nomination only and are comprised of a diverse group of recognized women leaders in their respective fields.Carrie co-authored the acclaimed NYSBA report adopted by the American Bar Association “If Not Now, When? Achieving Equality for Women Attorneys in the Courtroom and in ADR” and the follow-up report “The Time is Now: Achieving Equality for Women Attorneys in the Courtroom and in ADR.” She serves on the Steering Committee of the When There Are Nine Scholarship Project, which she co-founded with other SDNY alumnae to honor the late Justice Ruth Bader Ginsburg by providing law school scholarships and mentorship.<h4>Representative Experience</h4><ul><li>Government Appointments/Public Corruption. Appointments as independent counsel for federal, state, and local government agencies. Represents elected and appointed public officials, public entities, and individuals doing business with the government in a variety of public corruption-related matters with a focus on public-facing reports.</li><ul><li>Independent Monitor for the Federal Deposit Insurance Corporation related to workplace issues.</li><li>Special Independent Counsel to the New York City Council related to investigations of certain Council Members for misconduct and corruption.</li><li>Special Counsel to the MTA related to an examination of time, attendance, and overtime, which included presenting a report to the MTA Board.</li><li>Independent Counsel to the CA AG to conduct a review of its public release of confidential personal information associated with firearms permit holders and applicants, which included the preparation and release of a public report.</li><li>Service on the DOJ-appointed Monitorship Team for the global Odebrecht corruption matter.</li><li>Trial counsel for Rochester Mayor Lovely Warren for campaign finance charges; Hon. John A. Michalek for public corruption offenses; Hon. Sylvia Ash for obstruction of justice charges; County officials related to allegations of official misconduct and bid rigging.</li></ul><li>Financial Institutions/Securities Matters. Represents banks and other financial institutions in investigations of regulatory and consumer-related matters. Represents corporations and individuals in a variety of criminal investigations and regulatory matters involving federal and state securities laws.</li><li>Foreign Corrupt Practices Act (FCPA). Represents corporations in FCPA investigations across industries and in numerous jurisdictions. Service on the DOJ-appointed Monitorship team in the criminal prosecution of Odebrecht.</li><li>Workplace Misconduct. Conducts investigations for corporations and boards related to workplace misconduct and #MeToo issues and provides related advocacy and legal advice.</li><li>Cybersecurity. Conducts investigations of cybersecurity incidents and represents companies in related government and regulatory matters concerning disclosure of data and privacy issues.</li><li>RICO/Civil Fraud/Commercial Litigation. Represents a wide variety of public and private corporations in civil fraud, RICO, and commercial litigation including at trial. Represented UPS at trial in SDNY in a case brought by the NYAG and the City of New York alleging illegal transportation of untaxed cigarettes.</li></ul>

Carrie Cohen

Partner

Maria B. Earley is a financial services regulatory, enforcement, and litigation partner in the Washington D.C. office of Morrison Foerster.Maria is a former Consumer Financial Protection Bureau (CFPB) enforcement attorney with significant experience advising on issues related to consumer protection laws and emerging technology. She advises financial services and fintech companies with respect to product development, regulatory compliance, state and federal litigation, enforcement and examination, state licensing, and transactional matters.Maria works with early- and growth-stage startups as well as large incumbents, providing strategic, business-focused support and often serving as outside general counsel. Her advice spans a range of credit products, bank-enabled products, payments, income share agreements (ISA) and other alternative financing arrangements, and mortgage technology. She represents companies that touch all aspects of these products, including marketplace lending participants, program managers and investors, money transmitters, credit-reporting agencies, and numerous platform service providers.Maria leverages her experience as a former CFPB attorney to help companies navigate the complex and unique issues that arise when interfacing with the CFPB and other financial regulators. She has handled numerous matters involving federal and state regulators, including the CFPB, several state attorneys general, the California Department of Financial Protection and Innovation (CA DFPI) and other state regulatory agencies, the Federal Trade Commission (FTC), Office of the Comptroller of the Currency (OCC), and Federal Deposit Insurance Corporation (FDIC).Maria is committed to creating and sustaining collaborative, innovative, and inclusive environments in the legal community. She serves on the board of the Filipino American Lawyers Association of D.C. She previously served on the boards of the Legal Aid Society of D.C. and the Anacostia Watershed Society, and was co-vice chair of the Litigation and Arbitration subcommittee of the ABA’s Consumer Financial Services Committee.<h4>Representative Matters</h4><ul><li>Represent several companies in CFPB, OCC, FTC, and state enforcement actions concerning alternative lending technology, ISAs, payment services, credit reporting, banking practices, marketing practices, and for-profit education.</li><li>Lead counsel on litigation matters involving federal and state consumer protection laws, including EFTA, FCRA, RESPA, TILA, UDAAP and state credit and licensing laws.</li><li>Served as lead counsel in a True Lender litigation involving the Office of the Attorney General for the District of Columbia.</li><li>Advise fintech platforms and banks concerning strategic partnerships in connection with several as-a-service verticals, including lending, banking, and software.</li><li>Develop consumer and business financing programs for a range of assets, including energy efficient technology, mobile devices, alarm monitoring equipment, and POS systems.</li><li>Provide product development support, develop state licensing strategies, and advise on regulatory requirements related to alternative credit products, mortgage products, unsecured consumer lending, commercial lending, money transmission and ISAs.</li></ul>