Rachael Aspery advises consumer financial services clients – including banks, lenders, credit card companies, payment companies, and FinTechs – on a wide range of state and federal regulatory compliance matters. She supports clients as they develop new products, enter new markets, and pursue business growth, with a focus on mitigating regulatory, compliance, and litigation risk.
She works with FinTech and payments clients on regulatory requirements for innovative and nontraditional business models, including state licensing, lending, servicing, brokering, and money transmission activities. She also drafts and reviews policies and procedures, provides guidance on potential regulatory issues, and assists with examinations, investigations, and responses to state and federal regulators.
Prior to private practice, Rachael handled Bank Secrecy Act and Anti-Money Laundering (BSA/AML), sanctions, and core banking compliance matters. She also has experience in regulatory change management, risk management, banking operations, consumer and commercial lending, card services, treasury management, merchant services, and financial product development. She holds an MBA bringing both legal and business perspectives to client matters.
Professional & Civic Engagement
- American Bar Association, Business Law Section
- Business Law Today, Contributing Editor (Business Regulations & Regulated Industries)
- Business Law Today, Contributing Editor (Business Regulations & Regulated Industries)
Thought Leadership
Presentations
"Optimizing Bank Partnerships: Structuring Programs for Success," 24th Annual Consumer Finance Legal Conference, October 2025
“How to Write for Business Law Today: Publishing as Easy as ABC,” American Bar Association, Business Law Section Webinar, October 2024
Publications
Co-author, "Changes to NMLS Individual Disclosure Questions Take Effect," Business Law Today, May 15, 2026
Co-author, "4 True Lender State Laws And 1 Appeal For Fintechs To Watch," Law360, April 23, 2026
Co-author, "FinCEN Order Allows Banks to Collect Taxpayer Information from Third Parties," American Bar Association’s Business Law Today, July 2025, Month-In-Brief: Business & Regulated Industries, July 2025
Co-author, "FinTech Regulation: Follow the Law . . . and All These New Laws," American Bar Association Business Law Section’s The Business Lawyer, Volume 80, Issue 2, Spring 2025, June 2025
Co-author, "The Earned Wage Access Boom: Sixteen States Propose Legislation to Regulate These Types of Products," American Bar Association’s Business Law Today February Month-In-Brief: Business & Regulated Industries, February 2025
Co-author, "OCC Clarifies Bank Authority to Engage in Certain Cryptocurrency Activities," American Bar Association’s Business Law Today March 2025 Month-In-Brief: Business & Regulated Industries, March 2025
Co-author, "New York Department of Financial Services Issues Guidance on Customer Service Requirements for Virtual Currency," American Bar Association's Business Law Today Month-in-Brief, June 2024
Co-author, "Colorado DIDMCA Opt-Out Litigation: District Court Enjoins the Colorado Attorney General and Administrator of the Colorado Uniform Consumer Credit Code," ABA Business Law Today, June Month-In-Brief: Business Regulation & Regulated Industries, June 2024
Co-author, “FinTech Regulation: True Lender Legislation, DIDMCA Opt-Out, and Enhanced Federal Scrutiny,” American Bar Association, The Business Lawyer, Spring 2024, Volume 79 Issue 2, May 2024
Co-author, "FinCEN Seeks Information in Efforts to Modernize CIP Rule," American Bar Association’s Business Law Today April Month-In-Brief: Business & Regulated Industries, April 2024
Co-author, "Missouri and Washington Introduce True Lender Bills," American Bar Association'sBusiness Law Today Month-in-Brief, March 2024
Co-author, "Minnesota, Nevada, and Rhode Island Propose DIDMCA Opt-Outs," American Bar Association'sBusiness Law Today Month-in-Brief, March 2024
Author, "FinCEN Update to Beneficial Ownership FAQs and Paycheck Protection Program FAQs," American Bar Association’s Business Law Today January Month-In-Brief: Business & Regulated Industries, January 2024
Author, "New York Welcomes Close of First Unrestricted Cannabis Licensing Window with Fresh Lawsuit," American Bar Association’s Business Law Today December Month-In-Brief: Business Regulation & Regulated Industries, December 2023
Author, "FinCEN Issues Access Rule to Beneficial Ownership Information," American Bar Association’s Business Law Today December Month-In-Brief: Business Regulation & Regulated Industries, December 2023
Author, "FinCEN Extends Deadline for Companies Created or Registered in 2024 to File Beneficial Ownership Information Reports," American Bar Association’s Business Law Today December Month-In-Brief: Business Regulation & Regulated Industries, December 2023
Author, "FinCEN Issues Updated Beneficial Ownership Information FAQs," American Bar Association’s Business Law Today November Month-In-Brief: Business Regulation & Regulated Industries, November 2023
Author, "FinCEN Proposes Deadline to File Beneficial Ownership Information (BOI) Reports," American Bar Association’s Business Law Today October Month-In-Brief: Business Regulation & Regulated Industries, October 2023
Co-author, "Chapter 5: Closed-End Disclosures," American Bar Association (ABA)’s The Law of Truth in Lending (Fourth Edition), October 2023
Co-author, "PLI’s Consumer Financial Services Answer Book (2024 Edition)" Practising Law Institute, August 2023
Author, "FinCEN Releases Beneficial Owner Reporting Compliance Guide," American Bar Association’s Business Law Today September Month-In-Brief: Business Regulation & Regulated Industries, September 2023
Author, "Federal Reserve Board Provides More Information on Novel Activities Program," American Bar Association’s Business Law Today August Month-In-Brief: Business Regulation & Regulated Industries, August 2023
Co-author, "Interagency Guidance on Risks Associated with a Third-Party Relationship," American Bar Association's Business Law Today Month-in-Brief, June 2023
Author, "FDIC Issues Overview of Deposit Insurance System," American Bar Association’s Business Law Today May Month-In-Brief: Business Regulation & Regulated Industries, May 2023
Author, "OCC and FDIC Issue Guidance on Overdraft Fees," American Bar Association’s Business Law Today May Month-In-Brief: Business Regulation & Regulated Industries, May 2023
Author, "California DFPI Proposes Second Modification to Student Loan Servicing Regulations," American Bar Association’s Business Law Today March Month-In-Brief: Business Regulation & Regulated Industries, March 2023
Author, "FinCEN Invites Comment on Final Beneficial Ownership Information Reporting Rule," American Bar Association’s Business Law Today January Month-In-Brief: Business Regulation & Regulated Industries, January 2023
Co-author, "Federal Banking Agencies Issue Joint Statement on Risks Associated with Crypto-Assets," American Bar Association’s Business Law Today January Month-In-Brief: Business Regulation & Regulated Industries, January 2023
Co-author, "FinCEN Issues Final Rule Establishing Beneficial Ownership Information Requirements," American Bar Association's Business Law Today Month-In-Brief, October 2022
Co-author, "FinCEN and OFAC Issue First Joint Action in Cryptocurrency Market," American Bar Association’s Business Law Today October Month-In-Brief: Business Regulation & Regulated Industries, October 2022
Co-author, "FRB Proposes LIBOR Regulation," American Bar Association’s Business Law Today August Month-In-Brief: Business Regulation & Regulated Industries, August 2022
Co-author, "CFPB Launches New Office to Facilitate Competition and Innovation," American Bar Association’s Business Law Today May Month-In-Brief: Business Regulation & Regulated Industries, May 2022
Author, "Computer-Security Incident Notification Requirements for Banks Become Effective," American Bar Association’s Business Law Today May Month-In-Brief: Business Regulation & Regulated Industries, May 2022
Author, "President Biden Signs Executive Order on Ensuring Responsible Development of Digital Assets," American Bar Association’s Business Law Today March Month-In-Brief: Business Regulation & Regulated Industries, March 2022
Honors & Awards
- Recognized in Best Lawyers: Ones to Watch in America in Banking and Finance Law, 2026-Present
