Caroline M. Stapleton is Counsel in the Washington, D.C., office of Buckley LLP. Ms. Stapleton represents banks and nonbank financial service providers in federal and state regulatory and enforcement matters.
Ms. Stapleton regularly advises clients on compliance with a variety of consumer finance laws, including the Consumer Financial Protection Act (CFPA), Federal Trade Commission Act (FTCA), Truth in Lending Act (TILA), Real Estate Settlement Procedures Act (RESPA), Fair Credit Reporting Act (FCRA), Equal Credit Opportunity Act (ECOA), and the Fair Housing Act. In her consumer finance practice, Ms. Stapleton has worked with banks, savings associations, and nonbank lenders and servicers operating in a variety of spaces, including mortgage, credit cards, automobile finance, and student lending. Her experience includes:
- Performing compliance risk assessments of institutions’ origination, servicing, and marketing activities
- Preparing entities for compliance examinations by federal and state regulators
- Providing guidance regarding compliance with specific regulatory provisions in the development or expansion of financial products and services
- Responding to and defending enforcement actions by state and federal regulators based on consumer finance-related allegations
Ms. Stapleton also has experience with a wide variety of federal banking statutes and regulations, including the National Bank Act (NBA), Federal Deposit Insurance Act (FDI Act), Bank Holding Company Act (BHCA), and regulations promulgated thereunder. In her bank regulatory work, Ms. Stapleton has focused on questions regarding:
- The bank supervisory process at the state and federal levels
- How to respond to supervisory examination findings, including CAMELS ratings and Matters Requiring Attention (MRAs)
- Federal preemption of state laws applicable to national banks
- Permissible bank and bank holding company activities
- Treatment of confidential supervisory information (CSI)
Ms. Stapleton’s banking law practice additionally includes advising financial service providers on chartering options at the state and federal levels, including traditional state and federal bank and thrift charters, special purpose national bank charters for fintech companies and other qualifying entities, and alternative state bank chartering options such as industrial loan company (ILC), and industrial bank (IB) charters.
Prior to joining Buckley, Ms. Stapleton was an attorney-advisor in the litigation division of the Office of the Comptroller of the Currency (OCC), where she represented the OCC in civil litigation, bank receivership preparation, employment disputes, and other administrative contexts.
Ms. Stapleton received her J.D. from Duke University in 2011. During law school, she served as an Articles and Comments Editor for the Duke Journal of Constitutional Law and Public Policy. Ms. Stapleton received her B.A. from Duke University in 2007 (cum laude).
WASHINGTON, D.C. (Jan. 2, 2019) – Buckley Sandler LLP today announced the promotion of four associates to counsel, effective Jan. 1, 2019. “We are pleased to recognize these four outstanding attorneys who have consistently provided excellent service on behalf of our clients,” said Co-Managing...Press Releases
"Alternative data and fair lending face off: The relationship is complicated" by Jonice Gray Tucker and Caroline M. Stapleton (Mortgage Compliance Magazine)
Thinking of getting into a relationship with alternative data? You're not alone. Use of "alternate data," a term broadly used to describe consumer information gathered from non-conventional sources, is becoming increasingly attractive to mortgage lenders, their service providers, and even consumers...Articles
C-Suite Financial Services Review: Anchoring your compliance management system in today’s regulatory environment
Financial services companies have welcomed recent efforts by the federal government to minimize regulatory burden on the industry and view this trend as opening the door to innovation, development, and expansion. Among the most pressing questions these companies face as they explore new...C-Suite Review
On March 22, 2016, the U.S. Supreme Court issued a split decision (4-4) in Hawkins v. Community Bank of Raymore. The court’s one-sentence affirmance was a notable anti-climax in a case that had been viewed as likely to elicit guidance regarding limitations on deference to agency statutory...Articles
On June 25, 2015, the Supreme Court announced its highly anticipated opinion in Texas Dept. of Housing and Comm. Affairs v. Inclusive Comm. Project, Inc. The question presented to the Court was whether plaintiffs bringing suits under the Fair Housing Act (the “Act”) would be permitted to continue...Articles
On October 8, 2015, the Consumer Financial Protection Bureau (“CFPB”) published a compliance bulletin providing guidance to mortgage industry participants regarding the permissibility of marketing services agreements (“MSAs”) under the Real Estate Settlement Procedures Act (“RESPA”). The bulletin...Articles
The Real Estate Settlement Procedures Act has gone the "UDAAPified" way of debt collection — this time, through enforcement rather than guidance. In July 2013, Consumer Financial Protection Bureau Bulletin 2013-07 announced that the principles underlying the Fair Debt Collection Practices Act...Articles
Under the Federal Trade Commission’s original interpretation of unfair or deceptive acts or practices law, financial institutions could feel some sense of security that, if they provided a consumer with a clear understanding of a proposed transaction, the burden was on the consumer to determine...Articles
Deference in Decline: ECOA's Regulation B and Agency Discretion Might Not Be Broad Enough to Include Spousal Guarantors
For more than 40 years, the Equal Credit Opportunity Act (‘‘ECOA’’)1 has prohibited lenders from discriminating against applicants for credit on various prohibited bases, including marital status. The policy reasons for such protections, including ensuring that married women have full access to...Articles
- J.D., Duke University, 2011
- B.A., Duke University, 2007 (cum laude)
- District of Columbia
- New York
- Attorney-Advisor in the Litigation Division of the Office of the Comptroller of the Currency