Tom Scanlon
PEOPLE

Tom Scanlon

Of Counsel
scanlon.tom@dorsey.com

Overview

Tom focuses on helping financial institutions, fintech companies, and other clients on regulations for banking activities, payments systems, and consumer financial products and services.

Tom is experienced in counseling clients on ways to adapt financial products or services to changing rules, advising on transactions, and helping to address supervisory actions by the bank regulatory agencies, including the Consumer Financial Protection Bureau.

In both private practice and government service, Tom has worked on a range of bank regulatory issues and on projects relating to payments systems.  He also has advised fintech companies on compliance with federal and state laws that apply to a money transmitter.  

While serving at the Federal Reserve Board, Tom worked on a series of interagency rules; while serving at the Department of the Treasury, Tom worked as the principal attorney of the Department’s team to help draft the Consumer Financial Protection Act of 2010 (Title X of the Dodd-Frank Act).  He has worked with several types of clients to help shape public policy for financial regulation, such as by drafting legislative proposals and preparing comment letters for proposed rules.  

Tom has extensive experience advising on issues that involve the Federal Reserve’s regulations, the Federal Deposit Insurance Act, the National Bank Act, the Electronic Fund Transfer Act, the privacy rule (the Bureau’s Regulation P), the Fair Credit Reporting Act, the Military Lending Act, financial data aggregation, and vendor-management standards.

Education & Admissions

University of California, Berkeley, School of Law (Boalt Hall) (J.D., 1996)

University of California, Berkeley, School of Law (Boalt Hall) (Ph. D. candidate (Jurisprudence and Social Policy))

University of California, San Diego (M.A., Political Science, 1991)

University of California, San Diego (B.A., 1989), magna cum laude

Admissions

  • District of Columbia
  • Georgia

Languages

  • English, Italian (moderate speaking fluency) and Spanish (moderate speaking fluency)

Clerkships

  • United States District Court for the Middle District of Georgia, Law Clerk, Honorable W. Louis Sands, 1997-1999

Experience

  • Advise fintech companies on the OCC’s special purpose national bank charter, the OCC’s licensing procedures and examination process, and compliance with the Bank Holding Company Act.
  • For a national bank rolling out a product for consumers, advised on issues involving preemption of state laws by the National Bank Act.
  • Advised a bank on compliance with the FDIC’s rule for brokered deposits as the bank’s products scaled to broad base of end-user customers.
  • Advise banks and fintech companies on policies for handling consumer data under Regulation P and the Fair Credit Reporting Act, including for prescreened solicitations and furnishing to consumer reporting agencies.
  • Advised a bank on its strategy to respond to examination reports by the banking agency, and successfully addressed the agency’s concerns about possible violations involving sales practices and debt collection activities.
  • Supported a major bank on its enterprise-wide policies to streamline compliance with the Military Lending Act and the Servicemembers Civil Relief Act.
  • Advised a foreign bank on strategies for regulatory approvals to launch its banking operations in the United States.
  • Advised a major bank on approaches for its procedures to comply with customer due diligence requirements under the Bank Secrecy Act, including FinCEN’s rule for identification and verification of beneficial owners.
Tom Scanlon