A recognized dean of the consumer finance bar.Chambers USA
Jeremiah S. Buckley
Partner
Biography
Described by Chambers USA as "a recognized dean of the consumer finance bar," Jerry Buckley was a founder of Buckley LLP, the leading national financial services law firm that combined with Orrick in 2023, and is recognized as a thought leader in the field of financial services regulation.
A recognized dean of the consumer finance bar.Chambers USA
In The News
Rep. Suzan DelBene joins Jerry Buckley on privacy podcast
Jerry Buckley, a founder of Buckley LLP and co-host of the U.S. National Privacy Legislation podcast, interviewed U.S. Rep. Suzan DelBene (D-WA) about legislation she recently introduced that...
AnnouncementsJeremiah S. Buckley and Sasha Leonhardt discuss "Financial regulators’ dilemma: Regulatory modernization" during a Barefoot Innovation Group podcast
This podcast from the Barefoot Innovation Group features an interview with Jeremiah S. Buckley and Sasha Leonhardt on a major challenge facing financial regulators: Regulatory modernization. Click here to listen to the podcast .
In The NewsJeremiah S. Buckley quoted in American Banker article, “5 policy hurdles thwarting federal regulators’ fintech ambitions”
Jeremiah S. Buckley was quoted in an American Banker article, “5 policy hurdles thwarting federal regulators’ fintech ambitions,” which discussed a recent report developed by Buckley on behalf of the Alliance for Innovative Regulation on the top five legal obstacles for regulators to modernize...
In The News
Publications
"Put bank exam council in charge of data privacy" by Jeremiah S. Buckley (American Banker)
From the European Union to California and now other states and countries, data protection and privacy standards going into effect often share the same objectives, but have separate and different regulatory requirements. This creates a confusing array of legal requirements that pose compliance and...
Articles"Financial regulators’ dilemma: Administrative and regulatory hurdles to innovation" by Jeremiah S. Buckley and Sasha Leonhardt (George Washington University Law School: Business & Finance Law Review)
Developments in financial technology hold great promise to enhance the quality, delivery, and reach of consumer financial services. However, many of the laws dictating the operations of financial regulators are more than 50 years old, and in drafting these laws Congress understandably did not...
Articles"Congress needs to hurry up on data protection" by Jeremiah S. Buckley (American Banker)
Data is the lifeblood of the burgeoning digital economy. The debate about its use — and its protection — is now playing out globally. As big data, artificial intelligence and machine learning increasingly shape everyday lives, Congress will have some important policy choices to make, weighing how...
ArticlesJeremiah S. Buckley Authored an American Banker Article, "Secretary Mnuchin's Challenge: Rethink Consumer Finance"
Our nation's consumer finance laws, enacted nearly 50 years ago, are outdated. Reams of disclosures go unread and billions are spent by banks to comply with hypertechnical regulations. Perhaps more worrisome, the silent premise underlying many of these laws is that the key to assuring consumer...
ArticlesSpecial Alert: OCC Takes the Next Step Toward a Fintech National Bank Charter
On December 2, 2016, the Office of the Comptroller of the Currency (“OCC”) announced its plans to move forward with developing a special purpose national bank charter for financial technology (“fintech”) companies. Accompanying the Comptroller of the Currency, Thomas J. Curry’s announcement, the...
ArticlesSpecial Alert: Election Results - Preliminary Thoughts and Reactions
As a result of last Tuesday’s election, Republicans will control the White House and both houses of Congress in 2017. It is likely there ultimately will be some significant changes affecting financial services regulation and enforcement, but they will take time to implement. The President-elect has...
ArticlesSpecial Alert: D.C. Circuit Panel Rejects CFPB's RESPA Interpretation and Alters its Structure in PHH Corp. v. CFPB
On October 11, a three-judge panel of the U.S. Court of Appeals for the District of Columbia Circuit issued an opinion vacating a $109 million penalty imposed on PHH Corporation under the anti-kickback provisions of the Real Estate Settlement Procedures Act (RESPA), concluding that the CFPB...
ArticlesSpecial Alert: CFPB Proposes Amendments to Know Before You Owe/TRID Rule
On Friday, the CFPB issued its much anticipated proposal to amend the KBYO/TRID rule. The CFPB crowded dozens of proposed changes into the almost 300 page proposal, most of which are highly technical and require careful examination. As the Bureau has signaled since its intention to issue amendments...
ArticlesSpecial Alert: Maryland Ruling Opens New Front in Battle Over Bank Partnership Model
On June 23, the Maryland Court of Appeals affirmed a lower court judgment holding that a non-bank entity assisting consumers obtain loans from an out-of-state bank and then repurchasing those loans days later qualifies as a “credit service business” under the Maryland Credit Services Business Act (...
ArticlesThe Law of Electronic Signatures and Records, 2016 Edition
The Law of Electronic Signatures and Records is an essential guide to electronic signatures and records laws, including the context in which the laws were adopted and the ways in which the authors believe the drafters intended them to be interpreted. Buckley Sandler attorneys John Kromer and Jerry...
ArticlesSpecial Alert: CFPB Plans to Propose TRID Amendments in July
Director Cordray announced yesterday in a letter to industry trade groups that the CFPB has "begun drafting a Notice of Proposed Rulemaking (NPRM) on the Know Before You Owe Rule.” However, contrary to some reports, the proposal is not imminent. Instead, Director Cordray stated that the Bureau “...
ArticlesThe Compliance Officer Bill of Rights
Jeremiah Buckley authored "The Compliance Officer Bill of Rights," which was published Monday, February 22, 2016 in American Banker . Regulators and prosecutors are under increasing pressure to bring charges not only against companies, but also against individual corporate officers. Compliance...
ArticlesSpecial Alert: CFPB Director Opines on TRID Liability
On December 29, 2015, CFPB Director Richard Cordray issued a letter in response to concerns raised by the Mortgage Bankers Association regarding violations of the CFPB’s new TILA-RESPA Integrated Disclosure (“TRID”) rule, also known as the Know Before You Owe rule. In an effort to address concerns...
ArticlesThe Law of Electronic Signatures, 2014-2015 Edition
The Law of Electronic Signatures and Records is an essential guide to electronic signatures and records laws, including the context in which the laws were adopted and the ways in which the authors believe the drafters intended them to be interpreted. Buckley Sandler attorneys John Kromer and Jerry...
ArticlesSpecial Alert: CFPB Officially Delays TRID Rule Until October 3
The CFPB finalized a rule today that delays the effective date of the TILA-RESPA Integrated Disclosure (“TRID”) rule, including all amendments, from August 1 to October 3, 2015 . This is consistent with the proposed rule issued last month, which we wrote about here . The CFPB considered...
ArticlesSpecial Alert: CFPB Issues Proposal to Delay TRID Rule Until October 3
The CFPB issued a proposed rule today to delay the effective date of the TILA-RESPA Integrated Disclosure (“TRID”) rule, including all amendments, from August 1 to October 3, 2015. The proposed delayed effective date is two days later than the date announced last week so that the effective date...
ArticlesSpecial Alert: CFPB Will Propose to Delay TRID Rule Until October 1
Two weeks after declining requests from industry and members of Congress for delayed enforcement of the TILA-RESPA Integrated Disclosure (“TRID”) rule, the CFPB announced today that it will be issuing a proposed amendment to delay the rule’s effective date from August 1 to October 1, 2015. CFPB...
ArticlesSpecial Alert: CFPB Issues Statement on TRID Enforcement
On June 3, CFPB Director Cordray responded to requests from industry and members of Congress for delayed enforcement of the Bureau’s TILA-RESPA Integrated Disclosure (“TRID”) rule, which will take effect for applications received on or after August 1, 2015. The Bureau did not, as many had hoped,...
ArticlesSpecial Alert: CFPB States Supervisory Obligations Trump Nondisclosure Agreements
On January 27, the CFPB issued Compliance Bulletin 2015-01 to remind supervised financial institutions of their obligations concerning the disclosure of confidential supervisory information (CSI) to the CFPB and to third parties. Specifically, the Bulletin addresses the interaction between a...
ArticlesSpecial Alert: CFPB Finalizes Amendments to TILA-RESPA Integrated Mortgage Disclosures
On January 20, 2015, the CFPB finalized amendments to the TILA-RESPA Integrated Disclosure (“TRID”) rule that make a number of amendments, clarifications, and corrections, including: Relaxing the redisclosure requirements after a rate lock. The final rule permits creditors to provide a revised Loan...
ArticlesTo Restore Trust in Banks, Build Ethics Into Business Decisions
Trust is the bedrock upon which the banking business is built. However, revelations of unethical conduct at some banks have put that trust at risk. Senior officers of the Federal Reserve and other financial regulators recently met with management at leading banks to emphasize the need for a...
ArticlesSpecial Alert: CFPB Finalizes Points-and-Fees Cure and Other Mortgage Rule Amendments
Last week, the CFPB finalized an important amendment to its ATR/QM Rule that provides a mechanism for curing points-and-fees overages on qualified mortgage (“QM”) loans, as well as more minor amendments to its mortgage origination and servicing rules. The new rules, which were proposed in April,...
ArticlesSpecial Alert: Proposed Amendments to the TRID Rule and Introducing Buckley's TRID Resource Center
Buckley is pleased to announce our new TILA-RESPA Integrated Disclosure (“TRID”) Resource Center . The TRID Resource Center is a one-stop shop for TRID issues, providing access to Buckley's analysis of the TRID rule and the CFPB’s amendments, transcripts of CFPB webinars providing guidance on the...
ArticlesSpecial Alert: CFPB Bulletin Re-Emphasizes Focus on Mortgage Servicing Transfers
On August 19, 2014, the CFPB issued Bulletin 2014-01 to address “potential risks to consumers that may arise in connection with transfers of residential mortgage servicing rights.” The bulletin, which is the latest in a series of CFPB regulations, statements, and guidance on this subject, replaces...
ArticlesSpecial Alert: CFPB Issues Guidance on Supervision and Enforcement of Mini-Correspondent Lenders
This afternoon, the CFPB issued policy guidance on supervision and enforcement considerations relevant to mortgage brokers transitioning to mini-correspondent lenders. The CFPB states that it “has become aware of increased mortgage industry interest in the transition of mortgage brokers from their...
ArticlesSpecial Alert: CFPB Guidance States That Successors Are Not Subject to the ATR/QM Rule
On July 8, 2014, the CFPB issued an interpretive rule stating that the addition of a successor as an obligor on a mortgage does not trigger the Ability-to-Repay/Qualified Mortgage Rule (“ATR/QM Rule”) requirements if the successor previously received an interest in the property securing the...
ArticlesProcedural Protections for Individuals in Financial Enforcement Actions
In the five years since the financial crisis began, critics have argued that regulators aren’t doing enough to hold individual actors accountable for their conduct leading up to the crisis. These critics, however, may soon be appeased, with regulators promising to name names and hold individuals...
ArticlesSpecial Alert: VA Adopts Its QM Rule
On May 9, 2014, the Department of Veterans Affairs (VA) issued an interim final rule defining what constitutes a “qualified mortgage” (QM) for purposes of the loans it guarantees, insures, or originates. The VA stated that, to quell persistent uncertainty among lenders regarding the treatment of VA...
ArticlesSpecial Alert: CFPB Proposes Amendments to Mortgage Rules
On April 30, the Consumer Financial Protection Bureau (CFPB or Bureau) proposed targeted amendments to the Dodd-Frank Act mortgage rules that took effect in January 2014. Comments are due 30 days after publication of the proposal in the Federal Register. Ability-to-Repay/Qualified Mortgage Points...
ArticlesWhat Regulators Must Consider Before Punishing Individual Bankers
“Why aren’t we holding the individuals responsible for the financial crisis accountable?” It is a question that has been repeated so many times over the last five years that no one seems to expect an answer. But the question was raised again recently by Benjamin Lawsky, head of the New York State...
ArticlesSpecial Alert: HUD Adopts Its Own QM Rule
On December 11, 2013, the Department of Housing and Urban Development (“HUD”) issued a final rule defining what constitutes a “qualified mortgage” (“QM”) for purposes of loans insured by the Federal Housing Administration (“FHA”). With limited clarifications and adjustments, the rule tracks the...
ArticlesCFPB Finalizes Rule Combining TILA and RESPA Mortgage Disclosures
UPDATED OCTOBER 15, 2014: Updated to reflect amendments proposed by the CFPB on October 10, 2014. On November 20, 2013, the CFPB finalized its long-awaited rule combining the mortgage disclosures consumers receive under the Truth in Lending Act (“TILA”) and the Real Estate Settlement Procedures Act...
Articles
Awards and Recognitions
Awards & Recognitions
- Best Lawyers 2022: Banking and Finance Law, Financial Services Regulation Law, Litigation - Banking and Finance
- Best Lawyers 2021: Banking and Finance Law, Financial Services Regulation Law, Litigation - Banking and Finance
- Super Lawyers 2021: Banking, Consumer Law, Administrative Law
- Best Lawyers 2020: Banking and Finance Law, Financial Services Regulation Law, Litigation - Banking and Finance
- Super Lawyers 2020: Banking, Consumer Law, Administrative Law
- Best Lawyers 2019: Banking and Finance Law, Financial Services Regulation Law, Litigation - Banking and Finance
- Super Lawyers 2019: Banking, Consumer Law, Administrative Law
- Chambers USA 2018: Senior Statesman, Consumer Finance (Compliance)
- Best Lawyers 2018: Banking and Finance Law, Financial Services Regulation Law, Litigation - Banking and Finance
- Super Lawyers 2018: Banking, Consumer Law, Administrative Law
- Legal 500 2017: Recognized in the Financial Services: Regulatory practice area
- Chambers USA 2017: Senior Statesman, Consumer Finance (Compliance)
- Best Lawyers 2017: Lawyer of the Year (D.C. Litigation - Banking and Finance), Banking and Finance Law, Financial Services Regulation Law, Litigation - Banking and Finance
- Super Lawyers 2017: Banking, Consumer Law, Administrative Law
- Legal 500 2016: Recognized in the Finance - Financial Services: Regulatory practice area
- Chambers USA 2016: Senior Statesman, Consumer Finance (Compliance)
- Super Lawyers 2016: Banking, Consumer Law, Administrative Law
- 2015 Cornerstone Award, Electronic Signatures & Records Association
- Chambers USA 2015: Senior Statesman, Consumer Finance (Compliance)
- American College of Consumer Financial Services Lawyers 2015 Senator William Proxmire Lifetime Achievement Award
- Legal 500 2015: Recognized in the Finance - Financial Services: Regulatory practice area
- Super Lawyers 2015: Banking, Consumer Law, Administrative Law
- Best Lawyers 2015: Banking and Finance Law, Financial Services Regulation Law, Litigation - Banking and Finance
- Chambers USA 2014: Senior Statesman, Consumer Finance (Compliance)
- Legal 500 2014: Recognized in the Finance - Financial Services: Regulatory practice area
- Super Lawyers 2014: Banking, Consumer Law, Administrative Law
- Best Lawyers 2014: Banking and Finance Law, Financial Services Regulation Law, Litigation - Banking and Finance
- Chambers USA 2013: Senior Statesman, Consumer Finance (Compliance)
- Super Lawyers 2013: Banking, Consumer Law, Administrative Law
- Best Lawyers 2013: Banking and Finance Law
- Chambers USA 2012: Band 1, Financial Services Regulation: Consumer Finance (Compliance)
- Chambers USA 2010 and 2011: Band 2, Financial Services Regulation: Consumer Finance (Compliance)
- Chambers USA 2009: Band 2, Financial Services Regulation
- D.C.'s Top Financial Services Lawyers list, Washingtonian magazine 2009
- Who's Who in American Law
- Who's Who in the World
- Director at Large of the Exchequer Club of Washington, D.C.
Practice Areas
- Bank Counseling & Compliance
- Congressional Investigations
- Consumer Finance
- Consumer Financial Protection Bureau
- Enforcement Actions & Investigations
- Examinations
- Fintech
- Formation, Charter & Structure
- Licensing
- Mortgages
- Privacy, Cyber Risk & Data Security
- State Attorneys General
- Unfair, Deceptive, or Abusive Acts or Practices
Education
- J.D., University of Virginia, 1969
- A.B., Fairfield University, 1966
Admissions
- Connecticut
- District of Columbia
- U.S. Supreme Court
- U.S. Court of Appeals for the District of Columbia Circuit
- U.S. District Court, District of Connecticut
Government Service
- Republican Staff Director, U.S. Senate Banking Committee