April A. Breslaw
April Breslaw is a Senior Advisor with Treliant. She has held multiple leadership positions at federal financial regulatory agencies, including Deputy Assistant Director, Office of Supervision Policy, at the Consumer Financial Protection Bureau (CFPB), which she joined as it was being built in 2010. Her other roles have included Chair of the Consumer Compliance Task Force at the Federal Financial Institutions Examination Council (FFIEC); Associate Director, Compliance Policy and Examinations, at the Federal Deposit Insurance Corporation (FDIC); and Managing Director at the Office of Thrift Supervision (OTS).
April is deeply knowledgeable and well-positioned to assist financial services companies in addressing compliance risks and responding to regulatory, supervisory, and enforcement concerns. Her work with clients has included:
- Advising both banks and non-banks about how to transition effectively to CFPB supervision;
- Collaborating with companies to design strong Compliance Management Systems (CMS) and internal controls to improve operations, optimize the customer experience, and minimize exposure to regulatory enforcement actions and private litigation;
- Evaluating third-party oversight programs, including the adequacy of due diligence carried out as vendors, service providers, and other support business operations;
- Assessing and providing recommendations to enhance the governance, oversight, organizational structure, and culture related to retail sales incentive programs;
- Providing heightened insight into how all federal banking agencies view potential Unfair, Deceptive, or Abusive Acts or Practice (UDAAP) issues; and
- Alerting firms to emerging compliance risks, including the implications of regulatory proposals, guidance, and public statements made by the CFPB and other federal banking agencies about consumer protection issues.
April’s regulatory career included:
- Collaborating with senior members of CFPB Supervision and Enforcement to determine how to effectively correct violations of consumer financial laws, including consulting on the terms of remediation plans.
- Overseeing CFPB supervisory staff who examine for compliance with the consumer protection requirements applicable to the money transfer business. This included engaging with supervisory personnel across the country about the scope and direction of examinations and providing senior level review of examination reports and supervisory letters.
- Leading the OTS legal and policy team that, together with interagency staff, developed rules banning unfair credit card activities pursuant to the UDAAP prohibition. These rules laid the groundwork for the enactment of the Credit Card Accountability Responsibility and Disclosure Act (CARD Act).
- Evaluating whether potential violations of the Fair Housing Act (FHA) and Equal Credit Opportunity Act (ECOA) should be referred to the Department of Justice (DOJ).
- Leading the FDIC legal and policy team that worked with other agencies to develop rules and guidance to implement the Fair and Accurate Credit Transactions Act, which amended the Fair Credit Reporting Act (FCRA). These issuances addressed medical privacy, the accuracy and integrity of information reported to credit bureaus, the use of certain consumer information by affiliates for marketing purposes, and the steps necessary for covered entities to develop programs to detect, prevent, and mitigate identity theft.
April holds a JD from the George Washington University Law School and a BA with honors from the University of Miami.