Jeremy T. Rosenblum is Vice Chair of the Consumer Financial Services Group at Ballard Spahr LLP. For nearly 30 years, Mr. Rosenblums practice has focused on federal and state lending and consumer practices laws, with particular emphasis on the interplay between federal and state laws. Mr. Rosenblum has extensively counseled clients on the Dodd-Frank Act, including its upcoming restrictions on federal preemption of state law and debit card interchange fees and the implications of the creation of the Consumer Financial Protection Bureau; compliance with federal and state laws addressing overdraft fees, including laws prohibiting unfair and deceptive practices and guidance from the federal banking agencies; and the implementation of arbitration programs to minimize litigation risk.Mr. Rosenblums practice involves regular dealings with industry trade groups and regulators. In this regard, Mr. Rosenblum has drafted a number of amicus curiae briefs, to the U.S. Supreme Court and other courts, on behalf of a number of leading industry and business trade groups, including the American Bankers Association, the Consumer Bankers Association, the U.S. Chamber of Commerce, the Mortgage Bankers Association, the Financial Services Roundtable, the Clearing House Association and the American Financial Services Association. In 1998, Mr. Rosenblum obtained for Huntington National Bank a ground-breaking letter from the OCC concluding that national banks with offices in multiple states are permitted to charge the interest allowed by the laws of their home states upon compliance with minimal requirements. OCC Interp. Letter No. 822 (Feb. 17, 1998) (sometimes colloquially known as the Rosenblum Letter). This letter reversed OCC policy that, until that point, had required a highly fact-intensive analysis that hampered the ability of multi-state banks to export home state interest charges.Mr. Rosenblum has been honored each year since 2008 by The Best Lawyers in America 2008 and by Chambers USA: Americas Leading Lawyers for Business for his expertise in Financial Services Regulation and Banking and Finance. He is a fellow of the American College of Consumer Financial Services Lawyers, an organization founded to honor those lawyers who have made substantial contributions to the development of consumer financial services law, and is a long-time leader of the Consumer Financial Services Committee of the American Bar Association Section of Business Law, having previously served as Co-Chair of its Preemption and Federalism Sub-Committee (previously known as the Sub-Committee on Federal Preemption, Conflict of Laws, and Usury), Vice-Chair of its Interstate Delivery of Financial Services Sub-Committee and Vice-Chair of its Long-Range Planning Sub-Committee. Mr. Rosenblum is also a member of the Governing Committee of the Conference on Consumer Finance Law and one of the Financial Services Advisors to the Consumer Financial Services Law Report.Mr. Rosenblum is a graduate of Stanford University (A.B. in psychology, with honors, 1975), where he was elected to Phi Beta Kappa, and Yale Law School (J.D. 1979.
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