Overview
Allyson Baker serves as the Global Co-Chair of the Investigations and White Collar Defense practice at Paul Hastings, Co-Chair of the firm’s litigation practice in Washington, D.C., and as a partner in the Fintech & Payment and Investigations & White Collar Defense practices. Ms. Baker is a trial attorney, civil litigator, and counselor with significant experience in the federal government and private practice. She represents consumer finance companies and individuals in confidential, non-public investigations initiated by the Consumer Financial Protection Bureau’s (CFPB) Office of Enforcement, state attorneys general, the Federal Trade Commission (FTC), state banking agencies, and the Department of Justice (DOJ).
She also serves as litigation counsel for financial services companies, advises on consumer financial laws, and provides strategic and risk management counsel to consumer finance companies dealing with the CFPB and other federal and state law enforcement and regulatory agencies.
As part of her government experience, Ms. Baker spent time as an enforcement attorney at the CFPB, where she served as lead counsel in In the Matter of Discover Bank, which was one of the first enforcement actions in agency history and resulted in one of the largest agency settlements to date. She was a member of the initial team of attorneys hired to stand up the CFPB’s Office of Enforcement. As part of this effort, she helped formulate policies on litigation and investigations. She also led an office working group that created, reviewed, and coordinated research projects involving the application and jurisdiction of the Consumer Financial Protection Act and a group that coordinated the work of the Office of Enforcement and the CFPB’s Office of Fair Lending and Equal Opportunity.
Before joining the CFPB, Ms. Baker was a trial attorney with the DOJ Tax Division, where she served as a first-chair trial counsel in a number of jury and bench trials involving complex financial transactions, including a test case involving the sale of credit life insurance and other credit insurance products by credit unions.
Throughout her career, Ms. Baker has worked on some of the most significant and high-profile cases and investigations in the consumer financial services area. She also routinely counsels companies about all aspects of federal and state consumer finance laws. She advises companies about new consumer financial products and business models, and undertakes due diligence reviews. She has assisted companies and trade associations in their writing of comments for proposed CFPB rulemakings and requests for information.
Recognitions
- Benchmark Litigation, Litigation Star (2020 – 2025)
- Chambers USA, Financial Services Regulation: Consumer Finance (Enforcement & Investigations) (2023-2024)
- Benchmark Litigation, Top 250 Women in Litigation (2019 – 2022)
- The Best Lawyers in America, Financial Services Regulation Law (2019 – 2022)
- The National Law Journal, Litigation Trailblazer (2019)
- The Best Lawyers Business Edition, Women in the Law, Banking and Finance Law (2019)
- The Legal 500, Corporate Investigations and White-Collar Criminal Defense: Advice to Individuals (2024); Finance – Financial Services Regulation (2018 – 2020)
- DCA Live, Emerging Women Leaders in Law (2020)
- S. Department of Justice, Outstanding Attorney, Tax Division (2008 – 2010)
Education
- New York University School of Law, J.D. (cum laude), 2000
- Columbia University, B.A., 1995
- Columbia College Alumni Association Achievement Award
Representations
Litigation
- Served as lead counsel in CFPB v. Accrediting Council for Independent Colleges and Schools (ACICS), resulting in a victory in the D.C. Circuit Court of Appeals—the first time in decades that a federal appeals court had struck down an administrative subpoena issued by the federal government
- Served as co-lead counsel in John Doe et al. v. CFPB, winning affirmation in the federal district court for the District of Columbia, which upheld the client’s request to not reveal publicly the identities of the businesses suing the CFPB—the first time that a court had granted John Doe status to a party challenging any aspect of a CFPB CID
- Served as lead counsel in ACICS v. Dep’t of Education; obtained remand of a federal agency’s decision involving the accreditor of institutes of higher education in U.S. District Court for the District of Columbia. The Court held that the agency had not complied with the Administrative Procedure Act
- Served as lead trial counsel in Integrity Advance, LLC et al. v. CFPB, one of the first cases before the CFPB’s administrative law judge, involving alleged violations of the Consumer Financial Protection Act and the Truth in Lending Act (TILA)
- Served as lead counsel in Center for Public Integrity v. TitleMax of Virginia, Inc., et al., resulting in affirmation in Virginia Supreme Court of an order denying a records request from a government body
- Served as co-counsel in United States v. Four Oaks Fincorp. Inc., et al., resulting in a favorable settlement for the bank and the holding company in an investigation and lawsuit arising under FIRREA—the first public action in the Department of Justice’s “Operation Choke Point” initiative
- Served as lead counsel in In the Matter of Discover Bank; obtained a $214 million settlement stemming from a joint CFPB-Federal Deposit Insurance Corporation (FDIC) investigation into the sales and marketing of add-on credit card products—one of the first enforcement actions in CFPB history and one of the largest settlements to date
- Served as lead trial counsel in United States v. Stover; obtained an injunction against a promoter of fraudulent tax structures involving retirement plans and pass-through entities, with an estimated tax harm of hundreds of millions of dollars
- Served as lead trial counsel in United States v. Davison; obtained an injunction against a promoter of fraudulent tax structures involving retirement plans, pass-through entities, and farm‑related tax deductions, with an estimated tax harm of hundreds of millions of dollars
- Served as lead trial counsel in Community First Credit Union v. United States; defended the government’s position in a test case challenging an IRS determination about unrelated business income tax related to the sale of certain financial products
- Served as lead trial counsel in Saverin v. United States; obtained a directed verdict, resulting in a multi-million-dollar judgment for the government in trust fund recovery penalties and employment taxes
Investigations
- Counsel in CFPB investigations of companies and individuals in the student loan servicing, consumer lending, mortgage origination, and credit services industries
- Counsel in three separate non-public confidential CFPB investigations that were closed
- Counsel in non-public confidential Federal Trade Commission and state attorneys general investigations involving companies in numerous consumer financial services industries
- Counsel in numerous state regulatory agency enforcement actions involving companies in numerous consumer financial services industries
Matters may have been completed before joining Paul Hastings.
news
Recognitions
- Paul Hastings Ranked Top 5 in Global Investigations Review's "The GIR 30" 2022 - November 22nd, 2022
- Paul Hastings Named 'White Collar Group of the Year' by Law360 - January 27th, 2022
- Paul Hastings Championed as Most Impressive Investigations Practice by Global Investigations Review - November 10th, 2021
Engagement & Publications
- Speaker, “2024 Supreme Court Year in Review”, Financial Services Network of the Association of Corporate Counsel, 2024
- “The CFPB Lives But The Battle Is Not Over: The Supreme Court Decision and Its Implications” May 20, 2024
- Speaker, Virtual Law & Industry Conference, 2021
- Panelist, “Special Focus on State Enforcement Efforts and Examinations in the Prepaid Space,” American Conference Institute, 2021
- Panelist, "Diversity, Equity, & Inclusion" at the Politics & Payments Virtual Event, Electronic Transactions Association, 2020
- Speaker, ANA/BAA Marketing Law Conference, 2020
- Moderator, “LIBOR is Leaving in 2021: What You Need to Know,” Association of Corporate Counsel (ACC) Annual Meeting, 2020
- Panelist, "Growing Consumer Debt and How It Is Impacting Homeowners," Women in Housing & Finance Annual Symposium, 2020
Involvement
- Member, Fellows of the American Bar Association
- Board member, Women in Housing and Finance Foundation
- Member, Litigation and Business Law Sections, American Bar Association
- Served as vice chair of the American Bar Association’s Consumer Protection Law Developments (CPLD) Committee, and as the editor of the first CPLD chapter devoted solely to the CFPB