People

L. Jean Noonan
Partner
202.327.9700    
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Washington, D.C.
1909 K Street, NW
4th Floor
Washington, DC 20006
202.223.6930
Fax: 202.223.6935
Professional Experience

Jean is a partner in the firm's Washington, DC office. Jean advises clients on consumer financial services, fair lending, marketing, financial privacy, and consumer protection matters. She counsels financial institutions and others in complying with laws related to consumer credit, privacy, telemarketing, and unfair trade practices.

Jean represents clients in government investigations, examinations, and enforcement actions before federal agencies, including the Consumer Financial Protection Bureau, Federal Trade Commission, and federal prudential regulators, and in other ancillary matters.

Jean is a former executive with the Federal Trade Commission, where she directed the agency's enforcement of consumer financial services laws. She also served for a decade as the General Counsel of the Farm Credit Administration, an independent federal bank regulatory agency.

Jean has testified before Congress on legislative proposals relating to consumer financial services issues and lectures extensively on issues affecting financial institutions.

Jean is actively involved in many associations, including Consumer Financial Services Committee of the American Bar Association's Business Law Section; Chair, Federal and State Trade Practices Subcommittee; Vice-Chair, Privacy Subcommittee; Chair, Federal Trade Commission Activities Subcommittee; Vice-Chair, Federal Trade Commission Activities Subcommittee. Jean is a Founding Member and on the Board of Regents of the American College of Consumer Financial Services Lawyers (ACCFSL). She was Chair to the ACCFSL's Lifetime Achievement Award Committee and the Writing Competition Committee.

Jean is currently on the Government Committee for the Conference on Consumer Finance Law and was previously Council Chairman for the Town of Chevy Chase View, Maryland.

Jean is admitted to practice in Maryland and her practice in the District of Columbia is limited to matters and proceedings before federal courts and agencies in accordance with D.C. Ct. App. R. 49(C)(2) and (3).

Jean received her law degree in 1977 from the University of Texas School of Law. She holds a Bachelor of Arts with Departmental Honors from Oklahoma State University.

Education

University of Texas School of Law, Austin, Texas (Juris Doctor), 1977

Oklahoma State University, Stillwater, Oklahoma, B.A. with Departmental Honors, 1974

Professional Memberships and Activities

Consumer Financial Services Committee of the American Bar Association Business Law Section; Chair, Federal and State Trade Practices Subcommittee (2004 - 2006); Vice-Chair, Privacy Subcommittee (2002 - 2004); Chair, Federal Trade Commission Activities Subcommittee (1988 - 1992); Vice-Chair, Federal Trade Commission Activities Subcommittee (1986 - 1988), 1986 - Current

Founding Member, American College of Consumer Financial Services Lawyers, 1996; Board of Regents (1998 - 2002); Chair, Lifetime Achievement Award Committee (2002 - 2005); Chair, Writing Competition (2015).

Governing Committee, Conference on Consumer Finance Law, 2002 - Current

Council Chairman, Town of Chevy Chase View, Maryland, 2000 - 2003.

Speeches and Publications

"Fair Lending Developments: Whither Disparate Impact," The Business Lawyer (accepted for publication Spring 2016).

"House Committee Expressed Impatience with CFPB on Disparate Impact," Spot Delivery, November 2015.

"Another One Bites the Dust - Honda Finance Settles ECOA over Dealer Pricing Discretion," Spot Delivery, August 2015.

"Honda Finance's ECOA Settlement - What Does It Mean for Honda Dealers?" Spot Delivery, August 2015.

"Something for Everyone - The Supreme Court Rules on Disparate Impact," Spot Delivery, July 2015.

"A Complicated Compromise: The Supreme Court Rules on Disparate Impact," Basis Points, July 2015.

"CFPB Issues Flawed Examination Procedures," Spot Delivery, July 2015.

"Industry Calls Out CFPB on Dealer Reserve Discrimination Methodology," Spot Delivery, March 2015.

"CFPB and Indirect Auto Finance: Strategies for Mitigating Fair Lending Risk," Spot Delivery, March 2014.

"Fair Lending Developments: A Continuation and a New Beginning," The Business Lawyer, Spring 2015.

"No Harm Required - Glitches in Furnishing Credit Information Prove Costly," Spot Delivery, September 2014.

"FCRA Statute of Limitations Starts Anew with Each Dispute," Spot Delivery, June 2014.

"Fair Lending Developments: Is Disparate Impact Here To Stay?" The Business Lawyer, February 2014.

"Fair Lending and the CFPB's Prosecution of Ally - Where Do We Go From Here?" Spot Delivery, January/February 2014.

"Fair Lending Enforcement at the Department of Justice: Mortgage Lenders Under Fire," Basis Points, October 2013.

"Five Fair Lending Mistakes for Dealers to Avoid," Spot Delivery, October 2013.

"Transparency and the CFPB's Use of Proxy Data in Identifying Discrimination in Auto Finance," Spot Delivery, August 2013.

"Truth Prevails: Reporting Missed Payments During Bankruptcy," Spot Delivery, June 2013.

"U.S. Government Intensifies Fair Lending Enforcement," 18th Annual Consumer Financial Services Institute, Practicing Law Institute, May 2-3, 2013.

"Fair Lending Developments: Enforcement Intensifies, Class Actions Diminish," The Business Lawyer, February 2013.

"Who You Gonna Call? Risk-Based Pricing Notices and Dealers," Spot Delivery, December 2012.

"Responsibilities of a Furnisher - And We're Not Talking Interior Design," Spot Delivery, November 2012.

"What to Expect When Your Customer Is Expecting," Spot Delivery, June 2012.

"Don't Be a Babe in the Woods - Borrower Rights with Maternity Leave," Basis Points, June 2012.

"FTC Shines a Spotlight on Spot Deliveries," Spot Delivery, April 2012.

"Consumer Financial Protection Bureau: Love Triangle or Bermuda Triangle?" Spot Delivery, January/February 2012.

"Fair Lending Developments: Testing the Limits of Statistical Evidence," The Business Lawyer, February 2012.

"Failure to Truncate Account Numbers Not 'Publication' Covered by Insurance Policy," Spot Delivery, November 2011.

"Update on Current and Prospective Fair Lending Enforcement and Litigation Developments," Quarterly Report, Summer 2011.

"FTC to Auto Dealers: 'You are Kind of, Like, Um, Doing Okay,'" Spot Delivery, June 2011.

"Fair Lending Developments: Enforcement Comes to the Fore," The Business Lawyer, February 2011.

"Permissible Purpose Problem," Spot Delivery, August 2010.

"Fair Servicing - DOJ Focuses on Potential Discrimination in Loss Mitigation," Basis Points, June 2010.

"Information Safeguards: Five Steps to Avoiding Disaster," Spot Delivery, April 2010.

"Looking under the Hood of a Class Action Settlement," Spot Delivery, March 2010.

"Fair Lending: The End of Discretionary Pricing?" The Business Lawyer, February 2010.

"Recent Developments in Fair Lending: The Dawn of a New Litigation Era?" The Business Lawyer, February 2010.

"Spot Deliveries in the Crosshairs of Congress," Spot Delivery, June 2009.

"Firm Offers and Prescreening: Dealers Get a Break," Spot Delivery, June 2009.

"Auto Finance Marketing - Seventh Circuit Makes a U-Turn on Firm Offers," Spot Delivery, May 2008.

"Third-Party Liability for Federal Law Violations in Direct-to-Consumer Marketing: Telemarketing, Fax, and E-Mail," The Business Lawyer, February 2008.

CARLAW ® II: Street Legal, with others (Thomas B. Hudson, ed., 2008).

"Joint Users - Probably Not What You're Thinking," Spot Delivery, August 2007

"Credit Card Receipts: Is Your Slip Showing?" Spot Delivery, June 2007

"Profit-Based Pricing Supports Compliance," Executive White Paper, Nomis Solutions, May 2007

"A Scam for All Seasons: 'Seasoned Trade Line' Score Enhancement," Spot Delivery, April 2007.

"Fax, E-Mail, and Telephone: Federal Regulation of Marketing Methods," The Business Lawyer, February 2007.

CARLAW ® F&I Legal Desk Book: The Answer Book for Finance and Insurance Professionals, with others, (Thomas B. Hudson & Emily Marlow Beck, eds., 2006).

"Bankruptcy Discharge Lists - Good Business or Litigation Nightmare?" Spot Delivery, October 2006.

"Is Less Than Best Financing Rate 'Adverse Action' That Requires Notice to Customer?" Spot Delivery, April 2006.

"Fair Lending and the new HMDA Pricing Disclosures," The Business Lawyer, February 2006.

"Prescreened Offer of Credit Forms Basis of Class Claims," Spot Delivery, December 2005.

"Adverse Action - Are There Any Limits to the Notice Obligation?" Spot Delivery, September 2005.

"Recent Developments in Fair Lending and the ECOA: A Look at Housing and Motor Vehicle Dealer Participation," The Business Lawyer, February 2005.

"Federal Circuit Decision Muddles 'Prescreening' Requirements," Spot Delivery, January/February 2005.

"New Telemarketing Rules Pose Pitfalls for Dealers," Spot Delivery, July 2003.

"Federal Trade Commission Developments in Consumer Financial Services," The Business Lawyer, vol. 46, no. 3, May 1991.

"Federal Trade Commission Enforcement Activities," Retail Financial Services 1989, Practising Law Institute, 500 PLI/Comm 283, June 1, 1989.

"Federal Trade Commission Activity: Pursuing Unfair and Deceptive Practices in Consumer Financial Services," The Business Lawyer, vol. 43, no. 3, May 1988.

"Federal Trade Commission Enforcement Activities," Retail Financial Services 1988: Current Developments, Practising Law Institute, 460 PLI/Comm 751, June 1, 1988.

"Federal Trade Commission Enforcement Activities," Retail Financial Services: Current Developments, Practising Law Institute, 428 PLI/Comm 293, June 11, 1987.