Allen H. Denson

Partner
Denson, Allen

Allen Denson develops and implements strategies for financial institutions navigating regulatory examinations, investigations, enforcement actions, litigation, or inquiries by the Consumer Financial Protection Bureau (CFPB), Federal Trade Commission (FTC), federal banking regulators (OCC, FDIC, and the Federal Reserve Board), state attorneys general, and various state regulatory bodies. Allen has significant experience representing companies that provide consumer financial services, including lenders, sales finance companies, fintechs, banks, auto dealers, and other financial services companies. He also represents clients nationwide in litigation related to federal and state consumer financial law.

Allen previously served as a senior attorney at the U.S. Department of the Treasury’s Office of the Comptroller of the Currency, Enforcement & Compliance Division. There he handled all aspects of agency investigations, litigation, and regulatory inquiries involving both safety and soundness and consumer protection issues, against financial institutions and institution-affiliated parties. He advised bank supervision staff and senior agency officials regarding a wide range of issues arising under federal banking and consumer laws, including the Federal Deposit Insurance Act, Section 5 of the Federal Trade Commission Act, and the Equal Credit Opportunity Act. Allen also assisted examiners in the supervision and resolution of problem banks under OCC examination.

Experience

Government Experience

  • Senior attorney, Office of the Comptroller of the Currency, Enforcement & Compliance Division, U.S. Department of the Treasury

Representative Matters

  • Represented an installment lender in CFPB investigation concerning alleged violations of Section 5531 of the Dodd-Frank Act that was closed with no action and no liability
  • Represented a marketplace lender in a CFPB investigation concerning alleged violations of Section 5531 of the Dodd-Frank Act
  • Represented a payday lender in a CFPB examination and successfully convinced agency to reverse recommendation to refer matter to CFPB Enforcement
  • Represented an online lead generator in investigation by the FTC concerning alleged violations of the FTC Act
  • Represented an auto dealership group in an investigation by the FTC concerning alleged violations of the FTC Act
  • Represented a bank in an FDIC examination concerning alleged violations of the Electronic Funds Transfer Act and the FTC Act
  • Represented a bank in an OCC examination and successfully convince agency to upgrade CAMELS rating
  • Represented a creditor in litigation with the NY Attorney General concerning alleged violations of federal and state consumer protection laws
  • Represented a title lender in litigation with the California Department of Business Oversight
  • Represented creditor in class action litigation concerning alleged violation of state consumer protection laws
  • Represented online lender in mass arbitration concerning violation of consumer protection laws that was dismissed on a dispositive motion
  • Represented online lender in an investigation by the CFPB concerning alleged unfair, deceptive, or abusive acts or practices
  • Successfully negotiated a precedent-setting settlement against a bank that engaged in violations of Section 5 of the FTC Act through operation of its overdraft program
  • Conducted a bench trial seeking a civil money penalty against a former bank president concerning alleged violations of safety and soundness and consumer protection regulations

Insights

Credentials
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Education

  • J.D. magna cum laude University of Alabama School of Law 2008
    • Order of the Coif
    • Senior editor, Alabama Law Review
  • B.A. English cum laude College of William & Mary 2004

Bar Admissions

  • Alabama
  • District of Columbia
  • Virginia

Clerk Experience

  • Honorable Virginia Emerson Hopkins Federal District Court for the Northern District of Alabama

Professional Memberships and Activities

  • Young lawyer liaison, Federal and State Trade Practices Sub-committee, Consumer Financial Services Committee, American Bar Association