Tom joined Sidley from the Consumer Financial Protection Bureau (CFPB), where he served as Enforcement Director under both Republican and Democratic administrations. As the CFPB’s chief law enforcement officer, Tom was responsible for enforcing more than 20 consumer financial statutes and regulations, as well as the Consumer Financial Protection Act. He set and oversaw the legal and factual strategy in hundreds of active investigations and cases prosecuted by the CFPB’s Office of Enforcement and managed the agency’s 165 enforcement trial lawyers, investigators, and staff. As Enforcement Director, Tom commissioned and oversaw an initiative to centralize the Office of Enforcement’s investigative, litigation, and negotiation processes and best practices, which resulted in a comprehensive roadmap containing the strategy and methods that every CFPB enforcement attorney uses in opening and investigating matters, prosecuting cases, and determining penalties, redress, damages, and injunctive relief. He oversaw the setting of the CFPB’s enforcement priorities under both Republican and Democratic administrations, which will guide the Office of Enforcement in the coming years. He also led the first restatement of the CFPB’s Responsible Business Conduct bulletin, which allows companies to mitigate or obviate enforcement matters altogether. At the CFPB, Tom worked closely with the leadership at numerous other federal and state law enforcement agencies, including the U.S. Department of Justice, U.S. Attorney’s Offices, the U.S. Securities and Exchange Commission (SEC), the Office of the Comptroller of the Currency, the Federal Trade Commission, the consumer protection divisions of states attorneys general, and dedicated state consumer financial protection agencies such as the New York Department of Financial Services and the California Department of Financial Protection and Innovation.
Prior to his service at the CFPB, Tom served as a Deputy Assistant Attorney General in the Civil Division at the U.S. Department of Justice (DOJ), where he was counsel in many of the highest-profile, highest-value cases of the Consumer Protection, Torts, Commercial Litigation, Federal Programs, and Appellate branches. In Consumer Protection branch matters, Tom served in the role of a federal prosecutor enforcing the criminal laws of the United States. He is the only CFPB Enforcement Director who also served in leadership at DOJ on Consumer Protection branch matters, which is a key partner for CFPB criminal referrals arising from consumer financial cases and investigations. At DOJ, Tom managed more than 400 attorneys and staff and oversaw an active docket of more than 1,000 cases spanning the breadth of the Civil Division, including complex Financial Institutions Reform, Recovery, and Enforcement Act (FIRREA), False Claims Act (FCA), and Federal Tort Claims Act cases and investigations. As Deputy Assistant Attorney General, Tom was responsible for establishing priorities and best practices for defending and settling civil litigation in federal courts nationwide in consultation with the U.S. Attorney Civil Chiefs, as well as supervising and advising on litigation conducted by U.S. Attorneys’ Offices in delegated civil actions throughout the federal system.
For nearly two decades prior to his service with the government, Tom was an enforcement and litigation partner at a leading global litigation firm where he represented clients in complex enforcement investigations and cases, commercial litigation, and criminal proceedings, with a focus on financial and securities litigation, international litigation and investigations, professional liability defense, and bankruptcy litigation. During this time, Tom developed extensive experience in litigation and investigations arising from sophisticated financial and accounting frauds, including in matters involving the DOJ, the SEC, the Commodity Futures Trading Commission (CFTC), the Federal Deposit Insurance Corporation, and the Public Company Accounting Oversight Board. He served as lead counsel for international financial institutions and investment banks, multiple Am Law 100 law firms, the World Bank, and major global corporations.
Admissions & Certifications
- District of Columbia
- New York
- Columbia Law School, J.D., 1996 (Harlan Fiske Stone Scholar, Managing Editor, Columbia Journal of Transnational Law)
- Drew University, B.A., 1993 (summa cum laude)
- Diarmuid F. O'Scannlain, U.S. Court of Appeals, 9th Circuit (1997 - 1998)
- John G. Koeltl, U.S. District Court, S.D. of New York (1995 - 1996)