Lori Sommerfield brings more than 25 years of experience to her consumer finance practice, including leading one of the nation’s largest bank's fair and responsible lending programs, serving as in-house counsel at two other major financial institutions, and working as a staff attorney at the Federal Deposit Insurance Corporation (FDIC). As Senior Counsel in the Washington, DC office of Buckley Sandler LLP, she advises clients on consumer financial protection law, with an emphasis on fair and responsible lending regulatory compliance and Consumer Financial Protection Bureau (CFPB) matters.
Ms. Sommerfield practices extensively in the areas of fair and responsible banking — including the Equal Credit Opportunity Act (ECOA), the Fair Housing Act (FHA), and unfair, deceptive or abusive acts or practices (UDAAP) laws — and assists banks and non-banks in preparing for and managing compliance examinations by the CFPB and federal prudential regulators. In addition, she assists clients in defending fair lending investigations and enforcement actions. Ms. Sommerfield also advises financial institutions on development of compliance management systems (CMS), including consumer complaint management processes.
Among other things, Ms. Sommerfield’s legal representations have included:
- Performing fair lending reviews and fair lending risk assessments for major financial institutions and regional banks, either proactively or in response to formal or informal enforcement actions
- Creating or enhancing fair lending CMS programs, including legal advice on fair lending statistical analysis
- Conducting CFPB supervision and examination readiness reviews, including gap analyses, for banks, non-banks, and credit unions
- Managing, or providing assistance to financial institutions in managing, mortgage origination and servicing, CMS, and fair lending examinations by the CFPB and prudential regulators
- Representing banks and non-banks in CFPB indirect auto fair lending investigations and enforcement actions, including implementation of non-public memoranda of understanding
Prior to joining Buckley Sandler, Ms. Sommerfield managed Wells Fargo & Company’s Corporate Fair & Responsible Lending Compliance Program. During her time at Wells Fargo, she also served as Vice President and Compliance Manager for the Home & Consumer Finance Group’s Fair & Responsible Lending Compliance Program. She began her career as a staff attorney at the FDIC in Washington, DC where she worked in the Regulation & Legislation Section of the Legal Division developing banking policy and regulations.
Ms. Sommerfield is active in firm’s pro bono initiatives through her work with the Legal Counsel for the Elderly and is a member of the Board of Directors of the National Philharmonic Orchestra & Chorale. She received her J.D. from the Catholic University of America and her B.A. from the University of Minnesota.
Banks are beginning to receive demand letters from plaintiffs' lawyers that assert violations of the American with Disabilities Act (ADA) by not maintaining websites that provide appropriate access to consumers with disabilities. The demand letters rely heavily on an advance notice of proposed...Webcast
Jeffrey Naimon, Michelle Rogers, and Lori Sommerfield presented a “Mortgage Originations and Servicing Update” at Buckley Sandler’s eighth annual Fair Lending Today Conference on Monday, March 14, 2016 in Washington, DC...Speaking Engagement
Credit Union National Association Governmental Affairs Conference: What Does the Future Hold for Small Dollar Lending and Overdraft Protection?
Lori Sommerfield spoke at the Credit Union National Association Governmental Affairs Conference on Tuesday, February 23, 2016 in Washington, DC. Her panel was titled "What Does the Future Hold for Small Dollar Loans and Overdraft Protection?" Click here to learn more about this event.Speaking Engagement
Consumer complaint management has been top of mind for the Consumer Financial Protection Bureau since the agency opened its doors in July 2011. Through its public and non-public actions, the Bureau has clearly shown that it uses consumer complaints as a driving force in determining its priorities,...Webcast
Valerie Hletko and Lori Sommerfield spoke at Minnesota Banking Law Institute on April 10, 2015 in Minneapolis, MN. Their presentation was titled, “CFPB Update - Recent Developments and Predictions for the Future.” Click here to learn more about this event ...Speaking Engagement
National Association of Federal Credit Unions: 2015 Regulatory Compliance School - Fair Lending & Regulation B
Jeremiah Buckley, Lori Sommerfield, and Marshall Bell spoke at the National Association of Federal Credit Unions' 2015 Regulatory Compliance School, held March 30 - April 4, 2015 in Arlington. VA. Mr. Buckley discussed RESPA, Ms. Sommerfield discussed fair lending, and Mr. Bell discussed the Fair...Speaking Engagement
American Land Title Association's Business Strategies Conference - Best Practices for Consumer Complaint Management
Benjamin Olson and Lori Sommerfield will speak at the American Land Title Association’s (ALTA) Business Strategies Conference on March 19, 2015 in Philadelphia, PA. Mr. Olson's panel is titled, “CFPB Compliance in Implementation,” and Ms. Sommerfield's panel is titled, “...Speaking Engagement
Buckley Sandler Fair Lending Today Conference: Assessing Your Fair Lending and UDAAP Risk Under New Regulatory Expectations - What You Don't Know Can Hurt You
Jeffrey Naimon and Lori Sommerfield spoke at the firm’s 2015 Fair Lending Today Conference on Monday, March 16 in Washington, DC. Their panel was titled, “Assessing Your Fair Lending and UDAAP Risk Under New Regulatory Expectations - What You Don’t Know Can Hurt You.”...Speaking Engagement
John Redding, Michelle Rogers, Marshall Bell and Lori Sommerfield presented a Buckley Sandler webcast titled "The CFPB's Expanding Oversight of Auto Finance - Part I" on October 1, 2014. During its September 18th field hearing, the CFPB announced that its supervisory reach is expanding to include...Webcast
On March 17, Buckley Sandler hosted its annual Fair Lending Today conference. The full-day event covered fair lending and UDAP regulatory, enforcement, and litigation developments impacting mortgage originators and servicers, auto finance companies, credit card issuers, and consumer lenders...Speaking Engagement
When the CFPB opened its doors in July 2011, most banks and financial services companies within the Bureau’s jurisdiction were focused on preparing for their first round of compliance examinations under the new regulatory regime. Two and a half years later, most covered entities have experienced...Webcast
Buckley Sandler Fair Lending Today Conference: Fair and Responsible Banking Risk Management Evolving Best Practices
Buckley Sandler presented its 2013 Fair Lending Today Conference on April 8, 2013 in Washington, DC. Lori Sommerfield and Warren Traiger spoke on the "Fair and Responsible Banking Risk Management – Evolving Best Practices" panel. Click here to learn more about Fair Lending Today...Speaking Engagement
Andrea Mitchell and Lori Sommerfield presented a session titled "Fair & Responsible Lending in the Regulatory Crosshairs" at the Minnesota Banking Law Institute, on April 5, 2013 in Minneapolis, MN. The U.S. Department of Justice, CFPB, HUD and the prudential regulators continue to make fair...Speaking Engagement
On Thursday, December 6, 2012 from 2:00-3:15 PM E, Buckley Sandler LLP hosted a webcast to discuss the CFPB’s rules governing investigations, enforcement actions, and adjudications. Buckley Sandler attorneys Jeffrey Naimon , Jonice Gray Tucker , and Lori Sommerfield discussed themes prevalent in...Speaking Engagement
Buckley Sandler LLP hosted its eighth annual Fair Lending Today conference in Washington, DC on March 13-14, 2016. The two-day event featured an evening of interactive roundtable discussions on fair lending issues, followed by a full day of seminars. The sessions were led by Buckley Sandler...In The News
Washington, DC (Jan. 6, 2016) – Buckley Sandler LLP , a premier financial services, government enforcement and litigation law firm, announced today the promotion of 11 attorneys from three of the firm’s five offices, effective January 1, 2016. Katherine L. Halliday , Stephen M. LeBlanc and James T...In The News
Buckley Sandler LLP hosted its annual Fair Lending Today conference in Washington, DC, March 15-16, 2015. The two-day event featured an evening of interactive roundtable discussions on fair lending issues, followed by a full day of seminars. The roundtables and seminars were led by Buckley Sandler...Press Releases
David Baris, Margo H. K. Tank, and Lori J. Sommerfield Authored a Law360 Article, "ADA Compliance for Financial Institutions In The Crosshairs"
During the second half of 2016, numerous financial institutions of all sizes began receiving demand letters from plaintiffs firms representing disabled individuals and seeking settlements for violations of website accessibility standards related to Title III of the Americans with Disabilities Act (...Articles
David Baris, Andrea Mitchell, and Lori Sommerfield co-authored the Practical Handbook on Fair Lending for Bank Directors and Executive Officers , published by the American Association of Bank Directors. Although the concept of fair lending has existed since the late 1960s, in recent years the...Articles
On July 16, 2015, the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) launched the first in a new series of monthly complaint reports highlighting key trends from consumer complaints submitted to the CFPB. Importantly, its monthly report provides significant detail on the complaints the...Articles
To paraphrase a poem by the great Dr. Seuss, Oh, the places they’ve been. Oh, the places they’ll go! Consumer complaint management has been top of mind for the Consumer Financial Protection Bureau since the agency opened its doors in July 2011. Under the Dodd-Frank Act, matters related to the...Articles
Andrea Mitchell and Lori Sommerfield prepared a report for the American Association of Bank Directors that will help bank directors determine the red flags for fair lending risks. "Anyone who has been following enforcement activity in consumer financial services knows that fair lending is a key...Articles
The CFPB has identified consumer complaint data as a valuable tool in informing its consumer protection duties. It is taking steps to collect such data from various sources and has identified effective complaint management as a key component of a sound compliance program. This focus on consumer...Articles
Awards & Recognitions
- “40 Under 40” Award – Minnesota Business Journal for achievements in banking law (2004)
- J.D., Catholic University
- B.A., University of Minnesota
- District of Columbia
- Staff Attorney at Federal Deposit Insurance Corporation
- National Philharmonic Orchestra & Chorale, Member of the Board of Directors (2015-2017)
- Pro Bono Activities
- Legal Counsel for the Elderly