Aaron Kouhoupt has held a range of legal and compliance roles within banks and FinTech companies, providing him with direct experience in the operational and regulatory issues faced by financial services clients. His work includes applying existing legal frameworks to new financial products, building and operating bank compliance programs, and assisting foreign companies with launching U.S. banking and consumer finance products. His practice focuses on helping clients address legal requirements while taking business objectives into account. He regularly advises FinTech clients on regulatory compliance in the context of innovative products and services.
Aaron has more than 20 years of experience as both in-house and outside counsel to banks, FinTechs, and other financial institutions of varying sizes and structures. He represents marketplace lenders and other FinTech companies, as well as community, regional, and national banks, small loan companies, mortgage lenders and servicers, money transmitters, and payments processors.
He advises clients on regulatory compliance matters involving consumer loan documentation, e-commerce, underwriting, and advertising. A significant portion of his practice involves counseling both bank and non-bank participants in bank partnership arrangements. Aaron also advises on traditional banking and consumer finance matters, including issues arising under the Bank Secrecy Act (BSA), the Fair Debt Collection Practices Act (FDCPA), and the Fair Credit Reporting Act (FCRA), as well as on privacy, bankruptcy, and enterprise risk management.
Aaron has worked extensively with regulatory regimes applicable to emerging financial products. He previously served as Head of Legal at an alternative banking and digital payments company and held in-house roles at a peer-to-peer lending and alternative investing company. He also advises European companies seeking to launch consumer finance products in the United States.
Aaron has published articles and presented continuing legal education programs on a range of financial services and regulatory topics. He has also served as an Adjunct Professor at the University of Maine at Presque Isle, where he taught Business Law, Constitutional Law, and American Government.
Professional & Civic Engagement
- American Bar Association
- Business Law Section, Compliance Management Subcommittee, Chair
- Consumer Financial Services Committee
- Conference on Consumer Finance Law (CCFL), Governing Committee
Thought Leadership
Publications
- “FinCEN Order Allows Banks to Collect Taxpayer Information from Third Parties,” Business Law Today, Month-In-Brief: Business & Regulated Industries, American Bar Association, July 2025
- “The Earned Wage Access Boom: Sixteen States Propose Legislation to Regulate These Types of Products,” Business Law Today, Month-In-Brief: Business & Regulated Industries, American Bar Association, March 2025
- “Third Circuit Adopts “Reasonable Reader” Standard for Credit Report Accuracy,” Business Law Today, Month-In-Brief: Business & Regulated Industries, American Bar Association, August 2022
Presentations
- "Earned Wage Access - Federal and State Legislation and Enforcement Developments," ABA Consumer Financial Services Committee Business Law Section Winter Meeting 2026 (January 26, 2026)
- "Embracing the Role of Digital Identity in Open Banking," Nacha Payments Legal & Compliance Summit,” December 2025
- "Future of Finance Webinar Series: Routing Payment Innovation Within Regulatory Checkpoints," American Fintech Council The Future of Finance Webinar Series, July 2025
- "Avoiding Marketing Pitfalls," Online Lenders Alliance Tribal Lending Conference, May 2025
- "The CFPB’s Final Rules on Personal Financial Data Rights and Its Impact on Open Banking and Payments," Nacha's Smarter Faster Payments 2025, April 2025
- "Consumer Financial Services in Review and a Look Ahead," American Bar Association Webinar, November 2024
- "Regulation E Dispute Resolution," American Bar Association, Business Law Section, Consumer Financial Services Committee Winter Meeting, January 2023
Honors & Awards
- Recognized in the Chambers FinTech for FinTech Legal: Payments & Lending (USA - Nationwide), 2025-Present
- Named by Attorney Intel as a “Top 25 Financial Technology Attorney,” 2025