Overview

AJ Dhaliwal is a financial services regulatory and government enforcement partner based in Washington, D.C., and is the Co-Leader of Sheppard Mullin’s Consumer Finance Team and a member of the firm’s Chambers-ranked Blockchain and Fintech Team.

AJ is a highly regarded advisor who blends relentless advocacy with keen insight into achieving clients' goals, offering thoughtful and practical advice. AJ advises banks, fintechs, payment firms, mortgage companies, auto lenders, other nonbank firms, and their service providers, representing them in enforcement matters, including government investigations, regulatory exams, compliance issues, licensing, and mergers and acquisitions.

AJ represents financial institutions in government enforcement and regulatory matters before almost all governmental agencies, including the Consumer Financial Protection Bureau (CFPB), Federal Trade Commission (FTC), the US Department of Justice (DOJ), the US Department of Housing and Urban Development (HUD), the US Department of Veteran Affairs (VA), the Federal Housing Finance Agency (FHFA) and Government-Sponsored Enterprises (GSEs), Fannie Mae and Freddie Mac, the Government National Mortgage Association (Ginnie Mae), the US Small Business Administration (SBA), Federal Reserve Board (FRB), Federal Deposit Insurance Corporation (FDIC), Office of the Comptroller of the Currency (OCC), Financial Crimes Enforcement Network (FinCEN), state attorneys general and state regulators, such as the California Department of Financial Protection and Innovation (DFPI), the New York Department of Financial Services (NYDFS).

He has experience advising on matters involving the Equal Credit Opportunity Act (ECOA), the Real Estate Settlement Procedures Act (RESPA), the Truth in Lending Act (TILA), the Fair Credit Reporting Act (FCRA), Electronic Funds Transfer Act (EFTA), Electronic Signatures in Global and National Commerce Act (E-SIGN), Telephone Consumer Protection Act (TCPA), Servicemembers Civil Relief Act (SCRA), Military Lending Act (MLA), the Fair Debt Collection Practices Act (FDCPA), Gramm-Leach-Bliley Act (GLBA), Bank Secrecy Act/anti-money laundering (BSA/AML) laws and regulations, False Claims Act (FCA), and the Financial Institutions Reform, Recovery, and Enforcement Act (FIRREA). AJ frequently handles matters involving allegations of unfair, deceptive, or abusive acts in violation of the Federal Trade Commission Act (UDAP), the Consumer Financial Protection Act (UDAAP), and similar state laws. 

AJ regularly represents clients in the following areas:

Government Enforcement, Examinations, and Investigations: Guides financial institutions through CFPB and prudential bank regulatory examinations, enforcement matters, including self-disclosures, and advises on multi-agency investigations with state regulators, attorneys general, and other federal agencies. 

Regulatory Compliance: Navigates clients through the intricacies of compliance with federal and state consumer protection laws and regulations related to licensing, usury, advertising, disclosures, privacy, money transmission and payments, lending and servicing practices, and laws prohibiting UDAP/UDAAPS.

Fintech innovation: Assists established and emerging fintechs through the regulatory hurdles of product development, strategic partnerships, electronic payments, and with understanding the operational implications and compliance issues related to third-party risk management.

Transactions: Advises clients on negotiating commercial relationships, including joint ventures, and product development. He also advises acquirers in transactions on regulatory matters, including due diligence of companies, and transactional structuring in light of federal and state licensing and regulatory requirements.

AJ is active in Washington, D.C., with commitment to pro bono, community, and civic activity. He currently serves on the board of directors of the Washington Council of Lawyers. AJ is also on the Executive Committee of the South Asian Bar Association of North America (SABA).

Experience

Experience

  • Represented indirect auto finance company in a DOJ and state AG investigation into subprime auto loan origination and securitization practices
  • Represented several card issuers in CFPB enforcement actions relating to unfair billing tactics and deceptive marketing with respect to credit card add-on products
  • Represented a large student loan servicer in parallel federal government investigations, focusing on issues related to UDAAP and SCRA compliance
  • Represented a credit reporting bureau in a CFPB enforcement action alleging UDAAP violations relating to the marketing of credit scores to consumers
  • Represent financial institutions in connection with data breach and cyber matters, including in connection with related state regulatory and enforcement investigations into breaches
  • Represent multiple companies stemming from a CFPB sweep of investigations, which led to enforcement actions and negotiated settlements, alleging violations of the CFPA prohibition against deceptive acts and practices, the MAP Rule, and Regulation Z
  • Representation of multiple mortgage companies in FCA and FIRREA investigations by the DOJ, various U.S. attorneys’ offices, HUD, and VA, concerning compliance with the Fair Housing
    Administration (FHA) Direct Endorsement Lender program guidelines, VA loan requirements, HECMs, and Fannie Mae and Freddie Mac origination and servicing guidelines
  • Represented several banks and non-banks through CFPB examinations and pre-enforcement matters and responding to Proposed Action and Request for Response (PARR)
  • Represented a non-bank in a confidential bank regulator enforcement matter based on a referral from the CFPB to the DOJ for alleged fair lending violations
  • Responded to FDIC investigation subpoena on behalf of a national bank alleging RESPA violations arising out of co-marketing agreements and desk rentals
  • Defended residential mortgage lender in FCA qui tam litigation in Southern District of California regarding the FHA government-insured loan program
  • Representing large financial institution in connection with CFPB supervisory examination into fair lending activities
  • Advised multiple non-banks on issues related to their advertising and marketing practices in compliance with TCPA, TILA, the MAP Rule, and UDAP/UDAAP
  • Advised a FinTech payments processor on matters related to disclosure delivery, advertising and marketing compliance, and risk management
  • Represented major card issuer in identifying, self-reporting to CFPB, and remediating UDAAP non-compliance, resulting in the avoidance of a consent order and civil money penalties
  • Helped a card issuer redesign existing rewards program, create benchmarks against best in class standards, conduct risk assessments, integrate grandfathered balances, and terminate legacy programs
  • Advised credit, debit, and prepaid card issuers in compliance management, deferred interest, and technical compliance with consumer financial laws and regulations
  • Participated on due diligence teams to assess regulatory risks related to the acquisition of financial services entities, including mortgage originators and servicers
  • Representation of a bank in connection with an FDIC examination that alleged RESPA violations

Honors

Honors

Leading Author - Financial Services, Lexology Legal Influencers, Q2 2022, Q2 2024, Q4 2024, Q1 2025

Leading Author - Dispute Resolution, Lexology Legal Influencers, Q1 2024

Top Author, JD Supra Readers' Choice Awards, 2022-2025

Community Leader Award, South Asian Bar Association of Washington, D.C. (SABA-DC), 2021

Rising Star, South Asian Bar Association of North America (SABA), 2017

  • JD Supra Readers' Choice 2022
  • JD Supra Readers' Choice Top Author 2025
  • JD Supra Top Author 2023
  • JD Supra Top Author 2024

Insights

Articles

  • Co-author, The Supreme Court’s Ruling in Seila Law LLC v. CFPB: The End of CFPB Constitutionality Litigation? The Business Lawyer (Spring 2021)
  • Co-author, The devil is in the details: LabMD imposes limitations on the FTC’s enforcement authority, Cybersecurity Law Report (June 2018)
  • Co-author, The FCC’s Expanding Definition of Privacy, Journal of Internet Law (October 2015)
  • Co-author, Petitions To Modify or Set Aside CFPB Civil Investigative Demands: Analysis of Recent Decisions, LexisNexis® Emerging Issues Analysis (January 2013)

Consumer Finance and Fintech Blog Posts

Blockchain and Cryptocurrency: Law of the Ledger Blog Posts

Finance and Bankruptcy Law Blog Posts

Privacy Law Blog Posts

Government Contracts & Investigations Law Blog

Media Mentions

Speaking Engagements

  • Speaker, "FCC Changes TCPA Game for All! Critical Marketing and Servicing Calling and Texting Rules Update," December 10, 2024
  • Speaker, "WHF Lunch & Learn: Update on the Digital Design & Practices Under Heightened Reg Scrutiny," WHF, October 24, 2024
  • Speaker, "Fair Lending Model Validation and its Role with Fintech and Sponsor Banks," American Fintech Counsel, October 16, 2024
  • Speaker, "Dark Patterns: Update on Digital Design and Practices Under Heightened Regulatory Scrutiny," ABA Business Law Section Meeting, September 13, 2024
  • Speaker, "Junk Fees: Perspectives from Regulatory and Litigation Counsel," Client Presentation, September 9, 2024
  • Speaker, "FDIC Brokered Deposit Proposed Rule," American Fintech Council Brokered Deposit Ad Hoc Working Group, August 14, 2024
  • Speaker, "The New Age of Open Banking: AI + Privacy Considerations," South Asian Bar Association Annual Conference, July 13, 2024
  • Speaker, "Junk Fee Crackdown: Recent Regulatory Scrutiny of Junk Fees," American Bar Association, April 18, 2024
  • Speaker, "Beneficial Ownership Reporting: What Small Business Owners Need to Know," American Road & Transportation Builders Association, March 6, 2024

Memberships

Memberships

American Bar Association, Banking Law Committee

District of Columbia Bar Association, Board of Governors (2018-2021)

National Asian Pacific American Bar Association

South Asian Bar Association of North America

South Asian Bar Association of Washington, DC

South Asian Bar Association of North America, VP – Affiliate Relations

Digital Media

Education

  • LL.M., The George Washington University Law School, 2008
  • J.D., Western New England University School of Law, 2007
  • B.A., Simon Fraser University, 2001

Admissions

  • District of Columbia
  • Maryland
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