Maria B. Earley

Maria B. Earley is a financial services regulatory and enforcement partner in the Washington D.C. office of Morrison & Foerster.

Maria is a former Consumer Financial Protection Bureau (CFPB) enforcement attorney with significant experience advising on issues related to consumer protection laws and emerging technology. She advises financial services and fintech companies with respect to product development, regulatory compliance, state and U.S. federal enforcement and examination, state licensing, and transactional matters.

Maria works with early- and growth-stage startups as well as large incumbents, providing strategic, business-focused support and often serving as outside general counsel. Her advice spans a range of loan products, bank-enabled products, payments, income share agreements (ISA) and other alternative financing arrangements, and mortgage technology. She represents companies that touch all aspects of these products, including marketplace lending participants, ISA providers, program managers and investors, money transmitters, credit-reporting agencies, and numerous platform service providers.

Maria leverages her experience as a former CFPB attorney to help companies navigate the complex and unique issues that arise when interfacing with the CFPB and other financial regulators. She has handled numerous matters involving federal and state regulators, including the CFPB, several state attorneys general, the California Department of Financial Protection and Innovation (CA DFPI) and other state regulatory agencies, the Federal Trade Commission (FTC), Office of the Comptroller of the Currency (OCC), and Federal Deposit Insurance Corporation (FDIC).

Maria is committed to creating and sustaining collaborative, innovative, and inclusive environments in the legal community. She serves on the board of the Filipino American Lawyers Association of D.C. She previously served on the boards of the Legal Aid Society of D.C. and the Anacostia Watershed Society, and was co-vice chair of the Litigation and Arbitration subcommittee of the ABA’s Consumer Financial Services Committee.

Representative Matters

• Represent several companies in CFPB, OCC, FTC, and state enforcement actions concerning alternative lending technology, ISAs, payment services, credit reporting, banking practices, marketing practices, and for-profit education.
• Serve as lead counsel in a True Lender litigation involving the Office of the Attorney General for the District of Columbia.
• Advise fintech platforms and banks concerning strategic partnerships in connection with several as-a-service verticals, including lending, banking, and software.
• Develop consumer and business financing programs for a range of assets, including energy efficient technology, mobile devices, alarm monitoring equipment, and POS systems.
• Provide product development support, develop state licensing strategies, and advise on regulatory requirements related to mortgage products, unsecured consumer lending, commercial lending, money transmission and ISAs.
• Advised global payments provider on the scope and application of the remittance rule, various requirements under Regulation E, and updates to its terms of service.