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Thomas A. Brooks

Of Counsel

Washington, DC

1001 Pennsylvania Ave NW
Suite 1300 South
Washington, DC 20004
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Fax: 202.552.2379
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

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. He also works with banks that have cybersecurity issues to ensure they comply with regulators’ examination of IT policies and procedures.

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.

Selected and served as an Eisenhower Fellow working with Chinese banking regulators and bankers
Bar of the District of Columbia

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. 

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Newsletter Alerts
The OCC Jumps into the SandboxInnovation: Opening the Door for Regulatory EngagementBank Regulators' "Clarifying" Statement on Enforcing Supervisory Guidance The Banking Evolution Continues: OCC Opens Its Doors To Fintechs To Obtain A Special Purpose National Bank CharterTreasury Fintech Report Recommendations Could Change Banking As We Know ItNew York Federal Court Rules That The Bureau of Consumer Financial Protection Is Unconstitutional, Continuing A High-Stakes DebateOCC Encourages Lending to Underserved BorrowersDespite a Legal Setback - States Continue to Move Forward in Fintech Innovation“How’m I Doin?”—Treasury Secretary Mnuchin Doesn’t Need to Ask—He Will Tell You How Successful He Has Been With Regulatory ReformGuidance v. Rule: Congressional Review Act Invalidation of Auto Lending Bulletin Shows this Distinction Makes a Big DifferenceCyber Insurance: Don't Ignore This Point of Emphasis By Banking RegulatorsArizona Jumps Ahead of Other States In Financial InnovationChange in CFPB Structure Will Not Impact Fair Lending Enforcement; Compliance Does Not Take a Holiday CFPB is Constitutional, But Makes $100 Million Mistake In Interpreting the Law 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?No Real Surprises in CFPB's Final Rule for the Small Dollar Loan IndustryOCC Rescinds Guidance on Small-Dollar Loans: What Do Banks Do Now?If 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
“If the CFPB Is Remiss, the Court Must Dismiss” by Joann Needleman, Jane Luxton, and Thomas Brooks for For the Defense, DRI, February 2018."To serve your community or sit in jail: Is there any reward to this banking risk?" Financier Worldwide, March 2018. "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 2016"Marketplace Lending: How Will Regulators React?" Risk & Compliance Magazine, Jul-Sep 2016“Cyber Threats: The Foremost Risk Facing Banks and Their Directors Today,” Illinois Banker, May-June 2016Attorneys Thomas A. Brooks and Jane C. Luxton Quoted in "Under the Spotlight: Payday Ruling Could Foreshadow Marketplace Lending Regulations", Structured Credit Investor, June 2016The Capitol Forum article on M&T Bank/Hudson City merger - Tommy Brooks quoted
Presenter, "Banking in the US: Compliance and Opportunities for Foreign Banks," October 2017Alternative Lending: Regulatory Challenges Front and CenterNew Year – New CFPB TargetsWhat You Need to Know About the Consumer Financial Protection Bureau (CFPB) and Why You Should CareIs the CFPB Targeting You?