Jim has worked with a wide variety of financial institutions, from early-stage fintech lenders and payments companies to some of the largest banks in the country. His work is informed by his senior in-house roles at a global payments company and a leading AI-native fintech company, where he advised on legal and commercial strategy across a wide range of asset classes and products. In these roles, Jim served as a trusted adviser to the companies’ management, business, and product teams and led external-facing efforts with fintech and bank partners.
AI in Financial Services
Jim is particularly well versed in the use of artificial intelligence (AI) and machine learning (ML) in the realm of financial services, having helped fintech and financial services companies develop multiple AI-native products. He regularly provides product counseling from idea to launch. His work has included the development of model governance programs, overseeing and providing legal analysis on fair lending assessments, helping lenders develop adverse action and credit policy controls, refining LLM script controls to mitigate UDAAP risk, updating policies and procedures, and developing internal audit programs.
Consumer Financial Services and Lending
Jim’s core focus is advising clients on matters related to consumer financial products and services. He has extensive experience counseling bank and non-bank lenders and servicers across all major asset classes, including personal, student, auto, mortgage, revolving, solar, and small business lending. He has also worked on a number of alternative and emerging products, including buy now, pay later (BNPL), debt settlement, rent-to-own, and income share agreements. His advice has touched on the full panoply of consumer finance laws and regulations, including the Community Reinvestment Act (CRA), Equal Credit Opportunity Act (ECOA), Fair Credit Billing Act (FCBA), Fair Credit Reporting Act (FCRA), Fair Debt Collection Practices Act (FDCPA), Fair Housing Act, Gramm-Leach-Bliley Act (GLBA), Military Lending Act (MLA), Servicemembers Civil Relief Act (SCRA), state licensing laws applicable to lenders, servicers, and collections agencies, Truth in Lending Act (TILA), and prohibitions against unfair, deceptive, or abusive acts or practices (UDAAP).
Jim’s practice in this area is broad, with a particular focus on helping clients develop new products and mitigate regulatory issues related to existing ones. He also helps firms develop and improve their compliance management systems, conduct examination preparation and gap assessments, structure marketing review programs, analyze licensing requirements and obtain new licenses, and track legislative and regulatory changes.
Regulatory Due Diligence and Transactional Support
Jim has extensive experience working as regulatory counsel for loan purchasers, venture capital firms, investment banks, and other secondary market institutions in a range of transactions, including the purchase and sale of secured and unsecured consumer loans, financings, acquisitions, and initial public offerings of target fintech and consumer finance companies. This work frequently includes regulatory due diligence and transactional support. Jim has also advised investment committees on the risks posed by new or unfamiliar asset classes and strategic partnerships.
Jim brings this experience—coupled with his past experience in investment banking and as a capital markets attorney—to bear for consumer-facing fintech companies, helping them build strategic partnerships and compliance management systems that pass scrutiny from regulators, investors, and secondary market partners alike. He has also helped fintech companies present their compliance management systems to secondary market investors.
Payments
Jim has assisted bank and non-bank financial services companies in the payments industry with regulatory compliance, the development of new and novel products, contract negotiations, due diligence, and licensing. His clients have included major P2P payments platforms, prepaid card issuers, and remittance companies. In particular, Jim has advised on the Bank Secrecy Act (BSA) and anti-money laundering (AML) compliance, the Electronic Funds Transfer Act (EFTA), and the remittance transfer rule.
This work has spanned the development of new products, restructuring and updating user agreements, negotiating new partnerships and commercial agreements, and incorporating stablecoin into a previously fiat-only flow of funds. Jim has also conducted extensive regulatory due diligence on payment companies’ prospective partners.
Regulatory Enforcement and Examinations
Jim has represented clients in federal and state supervisory matters, investigations, and enforcement proceedings involving the U.S. Department of Justice (DOJ), Consumer Financial Protection Bureau (CFPB), Department of Housing and Urban Development (HUD), and California Department of Financial Protection and Innovation (DFPI), among others. He also has experience helping fintech companies that use a bank partnership model defend against pass-through examinations from bank regulators.
Government Relations
Jim has provided strategic regulatory counsel to national trade associations, helping them draft comment letters to regulators and lobbying materials related to proposed changes to consumer finance law. He also has experience helping advise these trade associations on the impact of potential regulatory changes.
Prior to Joining Venable: