Sidley is pleased to announce that Thomas Ward, who previously served as Enforcement Director at the Consumer Financial Protection Bureau (CFPB), has joined the firm as a partner in the Banking and Financial Services Group in Washington, D.C. As the CFPB’s chief law enforcement officer, Tom was responsible for enforcing more than 20 enumerated consumer financial statutes and the Consumer Financial Protection Act. He established and supervised the strategy in hundreds of active investigations and cases prosecuted by the CFPB’s Office of Enforcement and managed the agency’s 165 enforcement trial lawyers, investigators, and staff. Under his leadership, in 2020, the CFPB brought the second highest number of enforcement actions since its inception, secured its fourth highest amount of redress, prosecuted its largest and most complex litigation docket, and recommitted to enforcing the Fair Lending laws, including filing the first contested Fair Lending action in the CFPB’s history.
Tom is the only recent CFPB Enforcement Director in private practice and the only one with DOJ leadership experience in Consumer Protection Branch matters (which is a referral partner of the CFPB in criminal consumer finance cases). During his tenure at the CFPB, he commissioned a comprehensive effort to centralize all investigative, litigation, and negotiation processes and best practices; the critical thinking about each of the more than twenty enumerated statutes that the CFPB enforces and the Consumer Financial Protection Act; the thinking about the Consumer Financial Protection Act’s expansive UDAAP (“unfair, deceptive, abusive acts or practices”) authority; and how Enforcement thinks about and calculates remedies, penalties, redress, and injunctive relief. The result was a centralized and comprehensive roadmap of the Office of Enforcement’s practice that did not exist under prior Enforcement Directors or administrations. He also oversaw the setting of the CFPB’s enforcement priorities for 2020 under a Republican administration and 2021 under a Democratic administration, which priorities will guide the Office of Enforcement in the coming years, and led the 2020 restatement of the CFPB’s Responsible Business Conduct bulletin, which allows companies to mitigate or obviate enforcement matters altogether. Tom has deep substantive and procedural knowledge about the Bureau, the more than 20 statutes it enforces, the Consumer Financial Protection Act, and a unique understanding of the CFPB’s most pressing priorities and goals.