Brent Ylvisaker

Brent Ylvisaker




As an associate in Dorsey’s Finance & Restructuring Group, the types of areas in which he works include: banking regulations (e.g., affiliate transaction rules), consumer financial protection laws, Bank Secrecy Act and anti-money laundering regulations, financial data privacy and protection, state financial laws (including lending license requirements and usury laws) and e-commerce (e.g., E-SIGN and virtual currency).

Brent helps clients with financial regulatory matters by providing advice regarding the application of federal and state financial regulatory laws and requirements and restrictions imposed by such laws, reviewing internal compliance policies, drafting customer agreements/disclosures and communicating with regulators. His clients include state- and nationally-chartered financial institutions, bank holding companies, foreign banking organizations, consumer and commercial lenders, loan brokers and money services businesses.

Education & Admissions

University of Michigan Law School (J.D., 2011), magna cum laude
Contributing Editor, Michigan Journal of Law Reform

Winona State University (B.A. Political Science, 2007), summa cum laude


  • Minnesota


  • Helped a bank holding company develop a credit card program for its subsidiary banks by providing advice on state and federal laws regarding credit cards and drafting credit card agreements, applications and related disclosures.
  • Advised a national bank regarding anti-money laundering regulations applicable to foreign mission accounts, including customer due diligence requirements and AML program requirements.
  • Assisted a bank holding company with questions regarding the application and requirements of the Real Estate Settlement Procedures Act and Regulation X, including analysis of these laws with respect to various proposed mortgage lending activities by bank and non-bank subsidiaries.
  • Helped an OCC-regulated entity in the acquisition of several companies, including analysis of OCC regulations and guidance regarding acquisitions and equity investments and assistance in communicating with regulators, which ultimately resulted in obtaining regulatory approval for the acquisitions.
  • Provided advice to a depository institution regarding several deposit placement programs, including reviewing underlying program agreements and determining compliance with federal banking laws relating to pass-through insurance and Regulation D.
  • Provided advice to a foreign banking organization regarding a proposal to engage in new activities within the U.S., including analysis of activity restrictions under state law and federal banking law (e.g., Regulation K and Regulation Y), related approval and notice requirements and other regulatory consequences of engaging in the new proposed activities.
  • Provided advice to a commercial lender with respect to a proposed commercial lending program, including analysis of state laws regarding usury, choice-of-law provisions and unfair/deceptive acts and practices.
  • Assisted a rent-to-own company in updating its rent-to-own program, including analysis of federal laws (e.g., the Truth-in-Lending Act and Gramm-Leach-Bliley privacy rules) and state laws and drafting an updated rent-to-own agreement and accompanying disclosures.
  • Helped a bank holding company in preparing updated deposit account forms to be used by its subsidiary banks, including analysis of applicable federal and state laws and drafting deposit account agreements, change-in-term notices and other related documents.
  • Assisted a bank holding company regarding assertion of National Bank Act preemption with respect to activities of a national bank subsidiary, including analysis of federal preemption laws and helping prepare a legal memorandum to state regulators, resulting in state regulatory recognition of preemption.
  • Provided advice to an e-commerce business with respect to the development of a virtual points program, including analysis of state laws relating to stored value and money transmission, the Electronic Transfers Transfer Act and Regulation E and anti-money laundering regulations with respect to money services business and prepaid access; and recommendations for structuring the program based on this analysis.

News & Resources


Supreme Court Issues Midland Funding Decision
"Banks Appeal Fair Housing Act Case to Supreme Court," Consumer Financial Services Legal Update
"Can Credit Card Debt Collectors Continue to Charge Interest and Late Charges After Charging-Off the Debt?" Consumer Financial Services Legal Update
"Jesinoski Update: TILA Rescission in a Post-Jesinoski World," Consumer Financial Services Legal Update
"Update on Proposed Amendments to the Borrower Defense to Repayment Rule," Consumer Financial Services Legal Update
"The New '' for the Consumer Finance Industry," Consumer Financial Services Legal Update
The U.S. Supreme Court’s Decision in Texas Department of Housing & Community Affairs v. Inclusive Communities Project, Inc.
“Abusive” Development – Recent Applications of the Prohibition against Abusive Acts and Practices
Supreme Court’s Jesinoski Ruling Provides Clarity on TILA Rescission While Creating Many Questions
The CFPB issues proposed rules on prepaid products-E-Finance & Payments Law & Policy
CFPB Issues Proposed Rules for Prepaid Products
New York’s Proposed Regulation of Bitcoin Businesses - Polishing Up or Polishing Off?
Co-author, Visa’s New Designation Rules for Reloadable Prepaid Cards, E-Finance & Payments Law & Policy
Operation Choke Point: Recent Developments
Colorado Approves Financial Co-Op Plan for Marijuana Businesses
Bitcoin - Reward Comes With Risk - Part Four
CFPB & Indirect Auto Lending – The Saga Continues
Eighth Circuit Case Raises NBA Preemption Questions
CFPB Targets UDAAPs and Consumer Debt
FIRREA Civil Money Penalties
Consumer Protection Wherever You Pay: FTC Releases Mobile Payment Industry Report
CFPB Issues New Escrow Rules for Higher-Priced Mortgages
DC Circuit NLRB Ruling Calls CFPB Director’s Appointment Into Question
Fair Lending: Sixth Circuit Affirms Denial of Class Status on Commonality Grounds
FFIEC Issues Proposed Guidance on Social Media Use

News & Press Mentions

Super Lawyers Recognizes 36 Dorsey Lawyers in Minneapolis
Super Lawyers Recognizes 36 Dorsey Lawyers in Minneapolis
Dorsey Associate Brent Ylvisaker Comments on CFPB Guidance on Small Dollar Loans

Events & Speaking Engagements

New Law Series: Bitcoin Basics – Legal and Business Update

Select Presentations

  • The CFPB Takes on Prepaid: Proposed Amendments to Regulations E and Z (Co-Presenter) (Dorsey & Whitney Bank Counsel Roundtable, February 26, 2015)
  • 6 Things Every Business Lawyer Should Know about Dodd-Frank (Co-Presenter) (2014 Business Law Institute, May 5, 2014)
  • Bank Vendor Oversight (Co-Presenter) (Dorsey & Whitney Bank Counsel Roundtable, September 29, 2014)
  • Operation Choke Point: The Delegation of Enforcement Responsibility (and Liability) Continues (Dorsey & Whitney Bank Counsel Roundtable, April 23, 2014)
  • Indirect Auto Lending: The Potential Crackdown on Dealer Markups (Dorsey & Whitney Bank Counsel Roundtable, January 21, 2014)
  • Mobile Payments & Virtual Currency (Co-Presenter) (2013 Computer & Technology Law Institute, November 19, 2013)

Industries & Practices

Bankruptcy & Financial Restructuring
Cybersecurity, Privacy & Social Media
  • Banking & Financial Institutions
  • Bankruptcy & Financial Restructuring
  • Blockchain & Digital Assets
  • Consumer Financial Services
  • Cybersecurity, Privacy & Social Media
  • Development & Infrastructure
  • Financial Services Regulatory
  • Lending Transactions
  • Mortgage Banking

Professional & Civic

Professional Achievements

Brent participates in the following pro bono activities:

  • Housing Court Project
  • Conciliation Court Consumer Debt Clinic


  • Listed as a "Rising Star" by Minnesota Super Lawyers, 2017-2018

North Star Lawyer logo

  • MSBA North Star Lawyer, 2012, 2014-2017
Brent Ylvisaker