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David Stein
David A. Stein
Of Counsel
Washington +1 202 662 5074 dstein@cov.com Download V-card

David Stein advises clients on credit reporting, financial privacy, financial technology, payments, retail financial services, and fair lending issues. He assists a broad range of financial services firms, consumer reporting agencies, financial technology companies, and their vendors with regulatory, compliance, supervision, enforcement, and transactional matters.

Mr. Stein has significant experience advising clients on compliance with the FCRA, GLBA, ECOA, EFTA, E-Sign Act, TILA, TISA, FDCPA, Dodd-Frank Wall Street Reform and Consumer Protection Act, and FTC Act, as well as state financial privacy laws. Mr. Stein is a member of the firm’s fintech and artificial intelligence initiatives and works with clients on issues related to cutting edge technologies, such as blockchain, virtual currencies, big data and data analytics, artificial intelligence, online lending, and payments technology.

  • Provided advice to banks, consumer reporting agencies, and non-bank lenders on a broad range of credit reporting and financial privacy issues.
  • Provided advice to clients on the scope and requirements of the California Consumer Privacy Act.
  • Prepared a comment letter for a trade association client on the New York DFS’s proposed regulation of consumer credit reporting agencies.
  • Assisted a client respond to a New York DFS inquiry about registration as a consumer credit reporting agency.
  • Provided advice to a client in standing up a new consumer reporting agency and negotiating initial agreements with customers.
  • Assisted a client develop draft legislation to recognize the legal status of blockchain and blockchain records.
  • Advised digital gaming companies on the use of virtual currencies.
  • Advised a Fortune 500 company evaluate a bitcoin solution to cross-border fund transfers.
  • Prepared a white paper for a client addressing blockchain and its relationship to cybersecurity.
  • Advised a fintech company on regulatory engagement regarding artificial intelligence.
  • Provided advice to several fintech companies on consumer compliance, disclosure, and privacy issues in conjunction with to bank partnerships.
  • Provided advice to a small-business lender regarding fair lending and credit reporting issues.
  • Advised a national bank in responding to an OCC supervisory inquiry about sales practices and unauthorized account openings.
  • Prepared comment letters for trade association clients on the CFPB’s proposed arbitration rule.
  • Prepared comment letters for trade association clients on the CFPB’s proposed and final small-dollar lending rule.
  • Assisted a consumer reporting agency in preparing a compliance plan to satisfy the terms of a CFPB consent order.
  • Represented a regional bank in responding to FRB supervisory concerns regarding overdraft services.
  • Conducted readiness reviews or simulated exams to assist two consumer reporting agencies prepare for CFPB examinations.
  • Assisted a trade association evaluate and develop alternatives to proposed legislation adverse to members.
  • Advised a regional bank in responding to CFPB fair lending concerns related to a credit card portfolio.
  • Assisted a consumer reporting agency and a debt collector/debt buyer prepare compliance plans to satisfy the terms of CFPB consent orders.
  • Assisted a national bank prepare a comprehensive action plan to satisfy an OCC consent order on the marketing and sale of credit card add-on products.
  • Assisted a regional bank with a review of overdraft protection programs in preparation for a potential regulatory inquiry.
  • Advised a bank on regulatory risks of acquiring an institution with a military allotment business.

Memberships and Affiliations

  • American Bar Association, Consumer Financial Services Committee, Privacy Subcommittee, Co-Vice Chair (2015-2017), Chair (beginning 2017)
  • American College of Consumer Financial Services Lawyers, Fellow

Previous Experience

  • Promontory Financial Group, Director (2012-2015)
  • Consumer Financial Protection Bureau, Office of Regulations, Senior Supervisory Attorney-Advisor (2011-2012)
  • Board of Governors of the Federal Reserve System, Division of Consumer and Community Affairs, Managing Counsel (2008-2011), Counsel (2003-2008), Senior Attorney (2001-2003), Attorney (1999-2001)