Caroline M. Stapleton
Partner
Biography
Caroline Stapleton advises financial institutions in federal and state regulatory compliance, supervision and enforcement matters.
In The News
Buckley Sandler announces four counsel promotions for 2019
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
Publications
"Finance cos. should brace for wider CFPB anti-bias reach" by Caroline M. Stapleton (Law360)
The Consumer Financial Protection Bureau recently raised eyebrows when it broadly expanded the legal theories under which it will seek to challenge illegal discrimination in the financial services industry. The CFPB announced on March 16 that it revised its examination manual to identify...
Articles"Fairness gone viral: Fair lending considerations for financial institutions amid Covid-19" by Caroline M. Stapleton (American Bar Association Business Law Today)
The COVID-19 pandemic has had a disproportionate impact on certain protected classes in the United States, including, in particular, minority populations. Non-white populations have seen higher hospitalization rates, more deaths, and higher unemployment numbers over the past six months as compared...
Articles"Alternative data and fair lending face off: The relationship is complicated" by 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...
ArticlesC-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 ReviewInclusive Communities and Disparate Impact Under the Fair Housing Act
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...
ArticlesSpecial Alert: CFPB Issues Guidance Regarding Marketing Services Agreements
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...
ArticlesNew Day For RESPA: The UDAAPification Of Section 8
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...
ArticlesCaveat Emptor or Caveat Vendor? The Evolution of Unfairness in Federal Consumer Protection Law
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...
ArticlesDeference 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...
ArticlesPom v. Coke Will Impact Financial Services Too
Legal and compliance departments, take note: the U.S. Supreme Court’s recent decision in Pom Wonderful LLC v.Coca-Cola Co. confirms that even if an institution’s conduct meets the specific requirements established by the federal agency responsible for implementing one federal consumer protection...
Articles
Education
- J.D., Duke University, 2011
- B.A., Duke University, 2007 (cum laude)
Admissions
- District of Columbia
- New York
- U.S. Court of Appeals for the Ninth Circuit
Government Service
- Attorney-Advisor, Litigation Division, Office of the Comptroller of the Currency