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Thomas A. Brooks

Of Counsel
Office

Washington D.C.

1001 Pennsylvania Ave NW
Suite 1300 South
Washington, DC 20004
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Fax: 202.552.2379
Practice Areas
Administrative LawBanking & FinanceCybersecurity, Data Protection & Privacy
Areas of Emphasis
Administrative LawConsumer Financial Services Regulatory & ComplianceCuba Practice
Services
Information Governance 360
Education
J.D., Paul M. Hebert Law Center, Louisiana State University, Baton Rouge, Louisiana, 1969, AmJur Award in Insurance
B.A., The Colorado College, Colorado Springs, Colorado, 1966
State Bar Licenses
District of Columbia
Awards/Achievements
Selected and served as an Eisenhower Fellow working with Chinese banking regulators and bankers
Membership
Bar of the District of Columbia

Thomas A. Brooks

Of Counsel

Thomas A. Brooks concentrates his practice in financial services issues and represents clients before state and federal financial institution regulatory agencies as well as before Congress and the Executive Branch of government. His practice includes a wide variety of matters, including directors and officers liability issues, Dodd-Frank Act mandates, corporate governance requirements, BSA/AML issues, new financial services products, e-commerce, mergers and acquisitions, and a variety of other legislative and regulatory issues.

At the request of its board of directors, Tom led an investigation into the illegal activities by senior management of an undercapitalized bank. The investigation resulted in the prevention of the closing of the bank by the state regulator, led to changes in the corporate governance policies of the bank, and the filing of over 50 criminal referrals with the appropriate governmental agencies. These efforts required extensive negotiations with the state and federal regulators on behalf of the independent directors of the problem bank.

He has represented numerous financial institutions, directors and officers of banks and thrifts, and affiliated parties of depository institutions in enforcement matters brought by financial institution regulators as well as in monetary claims made against such individuals and entities. He was primarily responsible for the settlement of a $50 million claim brought by the FDIC against 34 former directors of a failed New York City bank. The claim was based on violation of laws and regulations, abusive insider transactions and negligence on the part of the directors. Tom led the steering committee of lawyers in these negotiations with the FDIC.

From 1981 to 1984, Tom served as General Counsel of the Federal Deposit Insurance Corporation as well as Legal Advisor of the Federal Financial Institution Examination Council. Prior to that time, he was General Counsel of the U.S. Senate Committee on Banking, Housing and Urban Affairs and Counsel of the Senate Subcommittee on Housing. His practice continues to be heavily involved in federal and state financial services regulatory issues.

Tom has testified before Congress on a variety of issues and has written articles for several publications including the American Banker, Bank Management and Banking Policy Report and was named to the Editorial Advisory Board of E-Money magazine.

Tom attended The Colorado College, where he earned a Bachelor of Arts degree, prior to earning his law degree from Louisiana State University Law School.

Experiences

Helped owners, investors, lenders and financial-services providers address the enforcement priorities of federal agencies, including the U.S. Department of Justice and the Financial Crimes Enforcement Network (FinCEN). We conduct comprehensive due diligence to ensure that businesses are duly licensed and registered and follow standard practices for the sale of recreational and/or medical marijuana. We also monitor business activities and public sources to identify suspicious activity or other red flags. 

Tags: Cannabis
Newsletter Alerts
The CFPB Takes No Holiday for Thanksgiving Leaving the Leadership of the Agency in DoubtWill CFPB Director Richard Cordray's Resignation Usher in a New Era of Financial Services Regulation?OCC Rescinds Guidance on Small-Dollar Loans: What Do Banks Do Now?No Real Surprises in CFPB's Final Rule for the Small Dollar Loan IndustryIf the CFPB is Remiss, the Court Must Dismiss: CFPB Must Provide Facts to Support Its Claims The CFPB's Final Arbitration Rule: Second Verse, Same as the First Treasury Department Issues Long Awaited Report on Regulatory Reform for the Financial Services Industry The Next CFPB Regulatory Challenge: Small Business LendingState Bank Regulators to the OCC: "Innovation" Starts in the States CFPB Ordered by a New York Federal Court to "Show Me the Money" OCC Creates New Special Purpose National Bank Charter as Comptroller Curry's Term Comes to an EndExtraordinary Opportunity for Bankers to Impact Federal Policy and Regulations OCC Final Receivership Rule Paves Way for Special National Bank CharterDC Circuit Issues Landmark Decision Holding the CFPB's Structure Unconstitutional: What Happens Next?OCC's Proposed Receivership Regulations for Uninsured National Banks Provide the Basis for a National Bank Innovative Lending CharterNew FDIC Study is Predictive of Upcoming Risk Management ExaminationsRegulators Issue New Guidance on Expectations of Deposit Reconciliations: Beware of the UDAAP ImplicationsUDAAP: Regulating the "Could've, Would've, Should've"Bank Directors Required to Face New (and Challenging) Information Technology DemandsBank Regulators Dial Up Concerns About Cyber-AttacksGAO Finds Deficiencies In Federal Bank Regulators' Examination ProceduresFFIEC Releases Cybersecurity Assessment ToolBank Examiners Will Be Strict In Enforcing Compliance With New Mortgage Disclosure RuleBank Boards of Directors Hit With Increased Responsibilities: Failure to Act Could Result in Enforcement Actions Against the Bank or Its Directors
News
Clark Hill PLC attorneys, Joann Needleman, Jane Luxton, & Tommy Brooks to present The New Regulatory Challenges Facing Small Business Lending: Navigating the New Frontier hosted by The Alternative Finance Bar AssociationClark Hill Attorney Thomas A. Brooks Published in Financier WorldwideClark Hill Attorney Thomas A. Brooks Published in Risk & Compliance MagazineSee More
Newsletter Alerts
The CFPB Takes No Holiday for Thanksgiving Leaving the Leadership of the Agency in DoubtWill CFPB Director Richard Cordray's Resignation Usher in a New Era of Financial Services Regulation?OCC Rescinds Guidance on Small-Dollar Loans: What Do Banks Do Now?See More
Presentations
Presenter, "Banking in the US: Compliance and Opportunities for Foreign Banks," October 2017Alternative Lending: Regulatory Challenges Front and CenterNew Year – New CFPB TargetsSee More
Trendpoints
Articles
"If The CFPB Is Remiss, The Court Must Dismiss" by Thomas Brooks, Jane Luxton, and Joann Needleman for Law 360, September 5, 2017 (Also featured in JDSupra August 30, 2017)"Bank Regulators' Concerns About Cybersecurity Has Not Abated: Greater Pressure on the Board of Directors in Expected," PA Banker, Winter 2016“Innovative Lending: Paving the Way for a New National Bank Charter,” Financier Worldwide Magazine, November 2016See More