Trevor R. Salter

Partner | Washington, D.C. | (202) 887-1527
(202) 887-1527

Trevor Salter focuses his practice on e-commerce and payments law. He helps nonbank and bank financial institutions go to market with new products and services that are compliant with the law as well as industry rules, such as card network rules and the ACH rules. Mr. Salter has significant experience counseling clients on mobile wallets, online and mobile banking, virtual currency, prepaid cards, remittance transfers, and electronic payments. In transactional matters, Mr. Salter frequently advises on strategic partnerships, card distribution and management agreements, and acquisitions.

Mr. Salter also represents financial institutions in examinations and enforcement actions by the Consumer Financial Protection Bureau and other regulators.

Mr. Salter started his career as associate counsel at a high-tech manufacturer in Silicon Valley.

Representative Matters

E-commerce and Payments

  • Represented a national bank in negotiations with a mobile wallet operator and counseled the bank on building a virtual prepaid card for the wallet.
  • Advised a national bank in designing and implementing a major cross-industry loyalty coalition program.
  • Represented a national bank in negotiations with a major electronic payments provider for the development of a mobile payments app.
  • Counseled a major credit card issuer on digital and text marketing and account acquisitions through online and mobile channels.
  • Represented a prepaid card issuer in negotiations with technology service providers, including negotiating the agreements, drafting policies and procedures, and drafting consumer notices and cardholder agreements.
  • Counseled a start-up online bank regarding compliance with consumer financial services laws, including requirements relating to deposit products, electronic contracting, website design and advertising, and online privacy.

Enforcement and Examinations

  • Represented a service provider to national banks in connection with a CFPB Civil Investigative Demand regarding credit card add-on products.
  • Represented a regional bank regarding an investigation by the Office of the Comptroller of the Currency into the bank’s practices relating to the marketing and sale of credit cards and third-party oversight.
  • Prepared a leading consumer reporting agency for examination by the CFPB, including assessing risks, drafting policies and procedures, and auditing activities for compliance with consumer financial services laws.
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