April Breslaw

April Breslaw is a Senior Advisor with Treliant. She has held leadership positions at multiple 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 built in 2010. She was also 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 help financial services firms address compliance risks and respond to supervisory, and enforcement concerns. Her work with clients has included:

• Alerting firms to emerging compliance risks, including the implications of regulatory issuances from the CFPB and other federal banking agencies about consumer protection issues;
• Advising both banks and non-banks about how to transition effectively to CFPB supervision;
• Designing strong Compliance Management Systems (CMS) to improve operations, optimize the customer experience, and minimize exposure to regulatory criticism or enforcement action;
• Evaluating third-party oversight programs, including the adequacy of due diligence carried out as vendors, service providers, and other support business operations;
• Identifying opportunities to increase the efficiency and effectiveness of complaint response and oversight programs, and align them with regulatory expectations and industry best practices; and.
• Providing heightened insight into how all federal banking agencies view potential Unfair, Deceptive, or Abusive Acts or Practice (UDAAP) issues.

April’s regulatory career included:

• Collaborating with senior members of CFPB Supervision and Enforcement to determine how to address violations of consumer financial laws, including the terms of remediation plans.
• Overseeing CFPB supervisory staff who examine for compliance with consumer protection requirements. This involved working with supervisory personnel on the scope and direction of examinations and providing senior level review of examination reports and supervisory letters.
• 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 programs to detect, prevent, and mitigate identity theft.
• Leading the OTS legal and policy team that, together with interagency staff, drafted 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).

April holds a JD from the George Washington University Law School and a BA with Honors from the University of Miami.