Robin Nunn

Robin has handled high-stakes cases on behalf of a wide range of clients, including banks, financial services firms, fintech companies, pharmaceutical companies, technology companies, and private equity firms in connection with civil trials and hearings, regulatory investigations and enforcement proceedings, state licensing, product development, regulatory compliance, examination, transactional matters, False Claims Act investigations, antitrust disputes and consumer protection lawsuits.

She also has experience in the statistical review and analysis of data and design and implementation of corporate compliance programs. She advises on privacy, cybersecurity, breach investigation, breach reporting and breach responses, and has assisted clients on compliance with the Truth in Lending Act (TILA)/Reg. Z, Equal Credit Opportunity Act (ECOA)/Reg. B, Truth in Savings Act (TISA), Home Mortgage Disclosure Act (HMDA), Fair Credit Reporting Act (FCRA)/Reg. V, Electronic Fund Transfer Act (EFTA)/Reg. E, Gramm–Leach–Bliley Act (GLBA), Fair Debt Collection Practices Act (FDCPA), Real Estate Settlement Procedures Act (RESPA), Servicemembers Civil Relief Act (SCRA), Unfair, Deceptive, or Abusive Acts or Practices Act (UDAAP), Community Reinvestment Act (CRA), Bank Secrecy Act (BSA), USA PATRIOT Act, Federal Trade Commission Act, Reg. K, Reg. O, Reg. W, Reg. Y, state money transmitter laws, state licensed lender laws, state unclaimed property laws, state prepaid access laws, and other federal and state laws and regulations.

 Robin has also represented individuals and institutions before a number of US agencies, including the Consumer Financial Protection Bureau (CFPB), US Department of Justice, US Department of Housing and Urban Development (HUD), Federal Trade Commission, Federal Reserve Board (FRB), Federal Deposit Insurance Corporation (FDIC), and Office of the Comptroller of the Currency (OCC), as well as state attorneys general and state banking regulators. She is often called on by the national media for commentary.

Robin is committed to creating and sustaining open, equal, collaborative, innovative, and inclusive environments throughout the world. She maintains an active pro bono and diversity and inclusion practice, and has been awarded a Pro Bono Publico Award for her representation of immigrant adults and children and led a prisoner rights case which led to the reversing of a wrongful dismissal in McPeek v. Blanchard (8th Circuit).

Before joining Morgan Lewis, Robin served as in-house counsel with two Fortune 500 companies. In those roles, she established and executed legal strategies for the company’s legal department, including on lawsuits and enforcement matters. She also counseled internal clients on legal issues across the business, including on cybersecurity, breach response, product design and launch, regulatory compliance, corporate governance, credit, operations, underwriting, and risk in a broad range of products including financial services, credit card, mortgage, auto, broker-dealer, and banking.

Litigation

• Global financial institutions on appeals in Section 1782 discovery actions
• Financial services companies in responding to subpoenas and complaints from various federal and state financial regulators alleging UDAAP violations
• A consumer payments fintech company in responding to a civil investigative demand (CID) from the CFPB
• A mortgage company in numerous class action lawsuits relating to foreclosures and lender liability claims
• Multiple clients in connection with litigation exposure and compliance issues regarding the Fair Credit Reporting Act and the Fair and Accurate Credit Transactions Act
• A financial institution in a class action, alleging the company placed calls in violation of the Telephone Consumer Protection Act and state consumer protection act laws
• A commercial and retail bank in connection with the US Department of Justice’s Operation Chokepoint investigation regarding alleged BSA/anti-money laundering violations
• Creditors, law firms and collection agencies in defending against claims under the FDCPA and state collection agency acts, including securing dismissal of dozens of claims

Supervision

• Many financial institutions in connection with responding to Proposed Action and Request for Response (PARR) and Notice and Opportunity to Respond and Advise letters
• A bank in connection with possible TILA violations related to its program for handling billing error disputes
• A large bank in connection with its response to a CID alleging violations of the FCRA
• A significant mortgage lender in HUD investigations of the Federal Housing Administration arising out of the foreclosure crisis
• A mortgage bank in a CFPB investigation action relating to HMDA
• A major fintech company in an inquiry regarding money transmission licensing requirements

Enforcement

• Citibank in a CFPB enforcement action alleging violations of the Credit Card Accountability and Responsibility and Disclosure Act of 2009 relating to credit card add-on products
• A financial institution in the CFPB supervisory and enforcement process leading to a stipulated consent order
• A national bank on a CFPB mortgage origination examination PARR Letter alleging violations of fair and responsible banking, including fair lending, ECOA, HMDA, RESPA, TILA, and UDAAP laws
• Large financial services companies in investigations and enforcement actions conducted by the CFPB
• A major financial services provider in monitoring compliance with a recent settlement with the OCC, FDIC, and FRB