Michael Nonaka

Michael Nonaka


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Covington & Burling LLP
One CityCenter
850 Tenth Street, NW
Washington, DC 20001-4956
Tel: +1 202 662 5727
Fax: +1 202 778 5727




  • University of Pennsylvania Law School, J.D., 2007
    • cum laude
    • University of Pennsylvania Journal of Constitutional Law, Articles Editor
    • The Wharton School, Certificate in Business and Public Policy
  • College of William and Mary, B.B.A./B.A., 2004

Bar Admissions

  • District of Columbia
  • Virginia

Michael Nonaka is an associate in the firm’s Financial Institutions and Privacy & Data Security practice groups.  He represents banks, financial institutions, and financial services providers on a wide variety of bank regulatory, enforcement, transactional, financial privacy, and legislative issues.  Mr. Nonaka has extensive experience advising clients on issues arising under financial services legislation such as the Dodd-Frank Wall Street Reform and Consumer Protection Act.

Representative Matters

  • Representation of large banks in connection with CFPB targeted examinations of credit card add-on products.
  • Representation of large banks in developing compliance programs and risk assessment programs for prohibitions on unfair, deceptive, and abusive acts or practices (UDAAP).
  • Representation of Wells Fargo in connection with a Federal Reserve Board investigation and consent order with respect to alleged falsification of customer income and customer steering by Wells Fargo Financial sales personnel in the origination of consumer mortgage loans.
  • Representation of Citigroup, Inc. and Citibank, NA, in connection with negotiation and implementation of OCC and Federal Reserve Board consent orders relating to consumer mortgage servicing and foreclosure activities.
  • Representation of banks and non-banks on anti-money laundering compliance matters.
  • Representation of General Motors in congressional hearings and requests for government funding.
  • Representation of Arlon Capital Partners LP in connection with investments in Grandpoint Capital, Inc. and Carlile Bancshares, Inc.
  • Representation of Freddie Mac in connection with establishment of Federal government conservatorship.
  • Representation of financial services company in merger and acquisition transactions with respect to financial privacy and data security.

Pro Bono

  • Represented indigent Florida inmate in post-conviction proceedings in state and federal courts.
  • Assisted the Washington Lawyers Committee in drafting and introducing legislation in the District of Columbia to reform certain aspects of the District’s parole and sentencing laws.

Memberships and Affiliations

  • Federal Bar Association, Member

Publications and Speeches

  • "Is Your Bank Increasing Its Credit Risk?," BankDirector.com (9/22/2014), Co-Author
  • "When The CFPB Is After You: How to Respond to Threatened Enforcement Actions," BankDirector.com (4/30/2014), Co-Author
  • "When The CFPB Is After You: How to Respond to Threatened Enforcement Actions," BankDirector.com (4/30/2014), Co-Author
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