Thomas Brooks


Thomas Brooks is a partner in the Washington, DC office of Lewis Brisbois and chair of the Bank Default Response Team, as well as a member of the Banking & Finance, Corporate, Commercial Lending, and the Securities and Corporate Finance Practices.

With more than 30 years of financial services regulatory practice, Tommy Brooks has represented a variety of commercial banks, thrift institutions, online lenders, fintech entities, money services businesses, consumer finance lenders and financial services trade associations. He has led a bank board’s internal investigation that led to the arrest and conviction for fraud of its president and chief lending officer. On behalf of a California financial trade association, he successfully advocated for owners of FDIC insured industrial banks to be exempt from Federal Reserve Board regulation.

In recent years, Tommy Brooks has increasingly focused on providing guidance and advice to clients in the rapidly changing financial institution regulatory environment. He has advised state banking associations on the proper use of the federal regulators’ cybersecurity assessment tool, and has represented a financial services trade association in developing and obtaining approval by the National Association of Insurance Commissioners of the Viatical Settlements Model Act. Other emerging areas in which he has been active include cannabis financing and consumer financial services regulated by the Consumer Financial Protection Bureau (CFPB) and, increasingly, state consumer regulatory counterparts.

Recent representative matters include:

  1. Assisting a multi-billion dollar fintech lender in obtaining an FDIC insured industrial loan bank charter
  2. Developing and implementing a successful strategy to enable a foreign bank to rebut a presumption of control in its acquisition of more than 10% of a money services business client that is licensed in 49 states
  3. Negotiating with a state money transmitter regulator in an enforcement action that resulted in the client’s avoiding a suspension of service proposed by the regulator
  4. Advising a UK licensed electronic money issuer on compliance with provisions of the California Financial Code
  5. Representing a bank in a unique acquisition of a trust company, structured over several years, that required multiple Federal Reserve Board approvals.

Tommy’s knowledge and insight of financial services law and regulation was initially formed while serving as General Counsel of the Federal Deposit Insurance Corporation, and prior to that as General Counsel of the U.S. Senate Committee on Banking, Housing and Urban affairs, the committee responsible for all federal banking, securities and consumer finance laws. The newly created CFPB has added a new level of regulatory scrutiny to financial services entities, imposing stringent new requirements and enforcement proceedings.

Banking is a highly regulated industry, and it is experiencing a time of disruption due to the advent of non-depository online lenders that use technology to provide new financial products and services to consumers and businesses. Some fintech entities partner with banks, some are acquiring banks, and some are converting operations to become insured banks. Tommy has the knowledge and experience to effectively guide clients in this fast changing environment.

Primary Area(s) of Practice

  • Banking & Finance
  • Commercial Lending
  • Securities & Corporate Finance
  • Administrative Law & Regulatory Practice
  • Corporate
  • Sustainability and Environmental, Social, and Governance (ESG) Practice
  • SEC Enforcement & Litigation
  • Ukraine Conflict Response
  • COVID-19: Contracts & Force Majeure
  • COVID-19 Response Resource Center
  • Bank Default Response Team

Additional Experience


District of Columbia


Bar of the District of Columbia

Awards & Honors

Selected and served as an Eisenhower Fellow working with Chinese banking regulators and bankers.

Professional Presentations

  • Presenter, “The Russia-Ukraine Conflict – A Legal Review," Dallas Bar Association, June 2023
  • Presenter, "One Year of The Russia-Ukraine Conflict – A Legal Review," February 2023
  • Presenter, "Banking in the US: Compliance and Opportunities for Foreign Banks," October 2017
  • Alternative Lending: Regulatory Challenges Front and Center
  • New Year – New CFPB Targets
  • What You Need to Know About the Consumer Financial Protection Bureau (CFPB) and Why You Should Care
  • Is the CFPB Targeting You?
  • Panelist, “NFTs Boom Or Bust: a Beginner's Guide to the New Gold Rush,” June 7, 2022.


Paul M. Hebert Law Center, Louisiana State University, Baton Rouge, Louisiana

Juris Doctor, 1969

  • AmJur Award in Insurance

The Colorado College, Colorado Springs, Colorado

Bachelor of Arts, 1966