Andrew C. Glass

/My focus

My multi-faceted approach to problem-solving delivers seamless solutions to clients’ legal challenges and assists businesses in achieving integrated solutions to managing risk. I work closely with clients’ business lines, and their legal, compliance, and information technology departments, to navigate complex regulatory areas confidently and efficiently, in areas that include:

• Advising investors in performing due diligence on regulatory, civil enforcement, and litigation matters in the acquisition of fintech and financial service companies
• Counseling fintechs and financial services companies on regulatory and compliance matters involving open banking/open finance and data privacy, artificial intelligence, fair lending laws, false claims act matters, credit reporting, and the Telephone Consumer Protection Act (TCPA)
• Representing fintechs in offering services to the highly regulated financial services industry and in helping fintechs grow their businesses to provide financial services directly to consumers
• Defending financial services clients, including mortgage lending and consumer credit institutions, in civil enforcement actions by the CFPB and other state and federal agencies and against private lawsuits and class action litigation of all types, including in connection with TCPA, False Claims Act (FCA), Real Estate Settlement Procedures Act (RESPA), Truth in Lending Act (TILA), Fair Housing Act (FHA), Equal Credit Opportunity Act (ECOA), Fair Credit Reporting Act (FCRA), Civil Rights Act, Racketeer Influenced and Corrupt Organizations Act (RICO), state unfair and deceptive acts and practices statutes, and common law claims
• Assisting clients in conducting internal audits and investigations, preparing for supervisory examinations, and responding to regulatory investigations
• Representing payments and lending companies in establishing bank partnership arrangements for providing tech-enabled financial services

My practice includes the defense of federal and state class action and government enforcement litigation for mobile wireless, telecom, and technology companies. These actions concern disputes arising under the federal Communications Act and Computer Fraud and Abuse Act, state unfair and deceptive acts and practices statutes (such as California Business and Professions Code § 17200), and common law claims, including actions involving the alleged unauthorized use of private personal information, the state tax billing disputes, misrepresentation claims, contract disputes concerning the assessment of surcharges, text messaging charges, and premium text messaging charges, and alleged violations of the number porting requirements of the Federal Communications Commission (FCC).

I have litigated a wide variety of securities law matters and complex commercial disputes, including contract, products liability, and civil rights matters.

/Representative experience

The below experience includes representations from previous law firm.

• Advising financial services and fintech clients regarding compliance with state and federal consumer protection acts, including state UDAP statutes
• Defending financial services and fintech clients in False Claims Act and enforcement actions brought by federal agencies, including by the Department of Justice, CFPB, HUD, and by state attorneys general
• Defending financial services and fintech clients against class action lawsuits asserting claims under FHA, ECOA, and credit reporting laws
• Representing financial services clients in responding to civil investigative demands and supervisory examinations by CFPB and other federal and state regulatory authorities
• Representing investors in exercising regulatory due diligence and assessing litigation risk in the purchase of financial services and fintech businesses regarding laws governing fair lending, artificial intelligence, privacy, and retail and mortgage banking products
• Advising national banking and financial services clients regarding compliance with HUD mortgage lending and servicing regulations
• Acting as national coordinating counsel for financial services clients in multiple class action lawsuits asserting irregularities in loan servicing practices
• Obtaining favorable outcome for financial services client in petition for certiorari to US Supreme Court, including preparing briefing to US Supreme Court and Eleventh Circuit Court of Appeals, regarding matter of first impression under the FHA
• Obtaining favorable outcome for fintech client in appeal to Third Circuit Court of Appeals regarding compliance with state banking law
• Obtaining unanimous decision in favorable outcome for financial services client in appeal to New York Court of Appeals in matter of first impression regarding application of New York tax law

/Looking ahead

Fintechs and financial services companies are on the cusp of embracing open banking, with the potential of allowing consumers to easily move their credit and depository accounts between service providers and allowing businesses to offer new, efficient financial services to consumers. Both existing businesses and new entrants to the marketplace will need to understand the rules of the road for complying with state and federal regulatory regimes and for minimizing exposure to lawsuits under state and federal consumer protection focused statutes.

/Clerkship

• Law Clerk to Chief Judge Paul J. Barbadoro of the United, States District Court for the District of New Hampshire

/Insights

Publications

• “Staying The Course On Consumer Financial Law Compliance,” Law360, April 21, 2025
• “The New ‘Open Banking’ Regime: Primer, Fact Sheet and Its Likely Future,” The Banking Law Journal, April 2025
• “Call For Input Shows How Banks, Fintechs Can Address Risks,” Law360, November 7, 2024
• “Applying Loper Bright, the Seventh Circuit Holds that ECOA Protects Prospective Applicants,” Westlaw Today, August 12, 2024
• “Third Time Is the Charm: Eleventh Circuit Allows Creditor’s Use of Commercial Mail Vendor,” The Banking Law Journal, January 2023 (co-author)
• “Mortgage Lending to Nontraditional Borrowers: The Opportunities and Compliance Points of Mortgage Lending to DACA Recipients, Recent Immigrants, and Limited-English Proficiency Borrowers,” The Banking Law Journal, April 2019 (co-author)
• “Massachusetts State Senators Seek to Enact Biometric Data Protection Law,” The National Law Review, February 2019 (co-author)

Speaking Engagements

• NYPAY (Panel About AI, Payments, and Data Monetization: Opportunities, Constraints, and Unknowns), July 2024
• Mortgage Bankers Association Legal Issues and Regulatory Compliance Conference (Panel about Fair Lending), San Diego, CA, May 2024
• Mortgage Bankers Association Compliance and Risk Management Conference (Panel about the Facts on Fair Lending), Washington DC, September 2023
• Mortgage Bankers Association Legal Issues and Regulatory Compliance Conference (Panel about major developments in Fair Lending), May 2023
• Mortgage Bankers Association Regulatory Compliance Conference, “General Session: Focus on Fair Lending and Servicing, Mortgage Bankers Association,” September 2021
• Mortgage Bankers Association Legal Issues and Regulatory Compliance Conference/Litigation Forum: Fair Lending, hosted by Mortgage Bankers Association, May 2021
• ACI Residential Mortgage Regulatory Enforcement & Litigation Conference; TCPA Challenges Impacting the Residential Mortgage Industry, Dallas, TX, September 2018
• Boston Bar Association: Supreme Court Mid-Year Round-Up: Important Decisions and a New Administration, Boston, January 2017