Jonathan D. Jerison counsels financial services clients on the consumer protection regulatory, legislative, and transactional matters that impact their business. As Senior Counsel in the Washington, D.C., office of Buckley LLP, he assists clients on a wide variety of consumer finance issues, including the Fair Credit Reporting Act (FCRA), the Truth in Lending Act (TILA), the Equal Credit Opportunity Act (ECOA), the Home Mortgage Disclosure Act (HMDA), the Gramm-Leach-Bliley Act privacy provisions, advertising and marketing (including telemarketing), and electronic commerce matters. He also defends clients facing government enforcement actions in these areas.
Mr. Jerison counsels bank and nonbank financial institutions, including mortgage lenders, servicers, insurers, and student lenders, in complying with federal and state consumer protection laws and regulations, and advises on fair lending and general regulatory issues, reviewing consumer disclosures and drafting amicus briefs and legislative and regulatory language advocacy papers.
Mr. Jerison has recently been involved in the following matters, among others:
- Assisting in representing consumer reporting agencies in Consumer Financial Protection Bureau (CFPB) and Federal Trade Commission (FTC) investigations, with an emphasis on issues involving the sale of ancillary products
- Assisting large financial institutions in connection with CFPB matters involving credit reporting practices
- Assisting the private banking units of large, internationally-active banks in addressing issues arising under the federal consumer laws, including assisting with FCRA and unfair, deceptive, or abusive acts or practices (UDAAP) issues raised by a new online mortgage platform and in remediating a potential problem arising under TILA
- Assisting startup fintech companies in all aspects of federal and state compliance
- Preparing a chapter on the revised HMDA rules as part of an American Bankers Association reference book
- Represented a credit reporting bureau in a CFPB enforcement action alleging UDAAP and FCRA violations relating to the marketing of educational credit scores to consumers and use of negative option billing
His prior experience includes 14 years in the Federal Trade Commission’s (FTC) Divisions of Financial Practices, Policy and Evaluation, and Enforcement, where he was responsible for enforcement, interpretation, and rulemaking involving the federal consumer finance laws and the Federal Trade Commission Act.
Mr. Jerison has been recognized in the area of Cyber Law (Data Privacy and Data Protection by Legal 500, which noted: “Jonathan Jerison is a foremost authority on FCRA and advising about risks under that law.”
Mr. Jerison received his J.D. from the University of California, his M.L.T. from Georgetown University School of Law, and his B.A. (cum laude) from Yale University.
A foremost authority on FCRA and advising about risks under that law.Legal 500
“Buckley attorneys are incredibly responsive while providing top quality legal services,” is how respondents described the firm in the 2020 edition of Legal 500, which ranked Buckley as a top law firm and recognized it in six categories:
- Corporate Investigations and White ...
Washington, DC (Jan. 6, 2016) – Buckley Sandler LLP , a premier financial services, government enforcement and litigation law firm, announced today the promotion of 11 attorneys from three of the firm’s five offices, effective January 1, 2016. Katherine L. Halliday of the firm’s Washington, DC...In The News
"Accurate FCRA reporting during Covid-19" by Marshall T. Bell, Jonathan D. Jerison, and Jessica L. Pollet (Bloomberg Law)
As financial institutions respond to a flurry of regulatory recommendations and mandates in response to the Covid-19 crisis, those relating to consumer reporting may be among the most difficult to decipher and operationalize. Federal and state authorities have made it clear that they expect...Articles
"Don’t let your shield down—FTC gets tough on EU-U.S. privacy shield framework" by Elizabeth E. McGinn, Jonathan D. Jerison, and Magda Gathani (Bloomberg Law)
The Federal Trade Commission took more enforcement actions related to the EU-U.S. Privacy Shield Framework in 2019 and the beginning of 2020 than it did in the prior three years combined. The FTC also has alleged deception in many cases where there was no indication that any misrepresentations...Articles
"Wearables present new realm of legal risks for teams" by Elizabeth E. McGinn, Jonathan D. Jerison, and John B. Williams, III (Sports Business Journal)
Reaching peak athletic performance is an increasingly scientific and quantitative pursuit, and professional sports franchises, which have tremendous financial and emotional motivation to be the best, are at the forefront in gathering as much data about their assets as possible. FitBits, Apple...Articles
On July 28, the CFPB announced that it is considering proposing a rule to “overhaul the debt collection market by capping collector contact attempts and by helping to ensure that companies collect the correct debt.” The CFPB released several related documents, including a report on third-party debt...Articles
Awards & Recognitions
- Legal 500 2020: Recognized in Cyber Law (Data Privacy and Data Protection)
- J.D., University of California, Berkeley, 1977
- M.L.T., Georgetown University, 1988
- B.A., Yale University, 1973 (cum laude)
- District of Columbia
- Staff Attorney in the Divisions of Financial Practices, Policy and Evaluation, and Enforcement at the Federal Trade Commission