J. Riley Key

Legal Assistant
Allison Hickman
P: 205.521.8925 ahickman@bradley.com

Riley Key’s practice focuses on counseling financial services clients facing regulatory and enforcement challenges in the mortgage, auto finance, debt collection, small dollar lending, and payments (credit cards, debit cards, prepaid cards, mobile payments, and cryptocurrencies) industries. Riley is a member of Bradley’s Banking and Financial Services Practice Group and is also a member of the firm’s Auto Finance and Payments industry teams. Through his broad range of experience, he has advised clients on matters related to unfair, deceptive, or abusive acts or practices (UDAAP), the Credit CARD Act, the Truth in Lending Act (TILA), the Real Estate Settlement Procedures Act (RESPA), the TILA-RESPA Integrated Disclosure Rule (TRID), the Telephone Consumer Protection Act (TCPA), the Fair Credit Reporting Act (FCRA), the Fair Debt Collection Practices Act (FDCPA), and the Electronic Funds Transfer Act (EFTA), as well as various other federal and state laws.

Riley focuses a substantial portion of his practice on assisting financial institutions as they prepare for and work through CFPB and other federal and state-specific supervisory examinations. This work has included conducting risk assessments, responding to requests for additional information, self-disclosing issues, working with examiners during on-site reviews, challenging examination findings, responding to Proposed Action and Request for Response (PARR) letters and supervisory letters, and, where appropriate, resolving issues through settlement. He has also assisted clients with the development of a comprehensive compliance management system.

Riley also frequently represents clients in regulatory compliance matters where he works closely with business, legal, and compliance leaders to identify compliance issues and develop workable solutions. By combining his compliance background and experience with examinations and bet-the-company matters, he is able to provide unique, practical insights regarding regulatory expectations and industry practices. As part of his compliance practice, Riley also provides general and targeted compliance training for various industry personnel, including boards of directors, legal and compliance personnel, and line-level employees.

Notable Matters
  • Bet-the-Company Matters: Negotiated successful outcomes in complex, national bet-the-company matters that resulted in settlements with 49 state attorneys general, the DOJ, CFPB, HUD, Executive Office of the United States Trustees, 48 state financial regulators, and other government parties. 
  • Targeted Compliance Reviews: Assisted a bank in reviewing all correspondence sent on auto loans, credit card accounts, and small dollar loans for compliance with applicable state laws.
  • Ongoing Compliance Efforts: Assisted a bank’s ongoing efforts to comply with various state and federal obligations related to late-stage collection efforts for a number of financial products, including credit cards and auto loans.
  • Examinations: Represented multiple financial services clients in successful CFPB examinations that allowed clients to avoid enforcement actions. 
  • Examination Preparation: Represented multiple financial services clients during internal compliance reviews to identify and correct potential compliance issues. Reviews included risk assessments and mock examinations to assist clients in preparing for anticipated regulatory scrutiny.