Overview
Rachael is a trusted advisor to financial institutions, fintech companies, and technology platforms navigating the complex legal and regulatory landscape governing consumer financial products and services. She counsels clients across the full product lifecycle, from concept and structuring through launch and servicing, bringing a practical business-focused approach to legal risk and compliance.
Rachael has extensive experience developing consumer-facing disclosures and terms for credit, deposit, and payment products, drafting and negotiating program agreements between banks and fintech partners, and advising on the design of innovative financial product structures. Her regulatory practice spans federal and state consumer protection and banking laws, including the Truth in Lending Act (TILA), Electronic Fund Transfer Act (EFTA), Fair Credit Reporting Act (FCRA), Equal Credit Opportunity Act (ECOA), Gramm-Leach-Bliley Act (GLBA), and Unfair, Deceptive, or Abusive Acts or Practices (UDAAP) standards, as well as a wide range of state lending, licensing, and usury laws. She frequently advises clients on multistate regulatory mapping, exemptions from state licensing requirements, state-specific disclosure mandates, and enforcement trends. She also regularly advises on true lender and bank partnership issues, including usury restrictions, licensing risk, and platform structuring considerations. Her work in this area includes drafting eligibility criteria, exclusion language, and other structural mitigants to address investor and rating agency concerns about state law exposure.
Rachael also supports clients facing scrutiny from federal and state regulators, including examinations and investigations conducted by the CFPB, OCC, FDIC, and state attorneys general. She advises clients on responding to supervisory findings, preparing regulatory submissions, and remediating compliance deficiencies. Her ability to bridge regulatory expectations with product execution makes her a key resource for clients.
In addition to her consumer credit experience, Rachael is skilled in commercial treasury management matters. She advises banks on the structuring, drafting, and revision of treasury management agreements, covering a wide range of commercial cash management services, including ACH origination, lockbox processing, and fraud prevention protocols. She also advises banks on the negotiation of vendor and third-party service provider agreements, including compliance with regulatory expectations under third-party risk management guidance.
Rachael has served as in-house counsel at a leading global technology company, where she advised on the development of new financial products and negotiated complex commercial and partnership agreements. Her in-house experience gives her an appreciation for internal cross-functional dynamics and the operational realities of bringing compliant financial offerings to market.
With a reputation for clarity, responsiveness, and sound judgment, Rachael is frequently sought after to structure programs in emerging legal gray areas and to help clients scale innovative financial solutions within a robust and sustainable compliance framework.
Experience
- Represented investment bank in a first-of-its-kind financing transaction involving collateral originated on blockchain.
- Assisted digital bank with the development and launch of the first-ever bitcoin rewards checking account.
- Assisted clients with obtaining and maintaining licenses required to conduct consumer and commercial lending and servicing activities.
- Advised financial service providers in developing compliant business practices involving the use and sharing of consumer data and consumer financial information.
- Performed regulatory compliance due diligence in connection with investments and acquisitions related to financial products.
- Prepared consumer-facing disclosures and terms and conditions for loans, credit cards, rewards and incentives programs, deposit accounts, and other financial products.
- Drafted and negotiated complex bank-fintech program agreements covering credit cards, installment loans, lines of credit, and embedded finance products.
- Advised on product design and structuring for BNPL, earned wage access, credit builder tools, and other innovative credit and payment offerings.
- Conducted multistate licensing analyses and regulatory mapping for nonbank lenders, loan brokers, servicers, and partners in bank-sponsored models.
- Counseled on state-specific usury restrictions, licensing exemptions, and consumer protection statutes affecting product design and enforcement risk.
- Provided strategic guidance on true lender issues, including risk allocation, control factors, and state law exposure in bank partnership and securitization contexts.
- Drafted exclusion language and eligibility criteria in securitization agreements to address true lender and state law compliance risks for investors.
- Advised clients undergoing regulatory examinations by federal and state banking agencies.
- Defended fintech and bank clients in connection with federal and state regulatory investigations.
- Reviewed advertising, referral, and promotional programs for compliance with TILA and UDAAP standards.
- Drafted treasury management agreements, including terms governing ACH origination, lockbox services, and fraud mitigation tools such as positive pay and security procedures.
- Negotiated commercial and technology agreements with issuing banks, program managers, payment processors, and data aggregators.
- Served as in-house counsel at a leading global technology company, advising on the development and launch of consumer financial products and supporting commercial negotiations with financial partners.
Accolades
Honors & Recognitions
- Recommended for FinTech, Legal 500 United States, 2024
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Education
JD, University of Mississippi School of Law, 2013
BA, University of Virginia, 2010
Admissions
District of Columbia
Texas
Virginia