Work
Emerging Issues & Strategic Innovation
In the field before the problem has a name. Moving before the framework exists.
The most consequential work I've done didn't start with a case or a rule. It started with a question nobody had quite asked yet — and the ability to act on it before a legal theory existed, before an agency had a framework, before the harm was visible at scale. Identifying the problem is only half of it. The other half is building something to address it, often from scratch and usually under time pressure.
"The most consequential work doesn't start with a case. It starts with a question nobody has quite asked yet."
Selected work
Four examples of emerging problems identified early, novel approaches developed to address them, and results that changed the terms.
Technology & Litigation
Building one of the first plaintiff-side document review tools
The problem
Large-scale consumer protection litigation generates document volumes that dwarf the capacity of traditional review. The tools that existed were built for defense-side work, at defense-side prices — leaving public enforcement advocates at a systematic disadvantage.
What we did
- Identified the technology gap early — before it became a recognized problem in public enforcement circles
- Built one of the first plaintiff-side document review systems combining early machine-learning tools with purpose-built workflow design
- Structured the system to let a small public enforcement team move at the speed and scale of large institutional adversaries
Significance
Changed the resource calculus for public enforcement. Demonstrated that technology could be a force multiplier for under-resourced advocates taking on well-resourced defendants — a model that has since become standard practice.
Infrastructure & Networks
Creating a student debt advisory and referral network at the NC AG's office
The problem
North Carolina borrowers had no organized way to get help navigating a student loan system that was actively working against them. The AG's office had enforcement capacity but no infrastructure for direct borrower assistance.
What we did
- Designed and built a statewide advisory and referral network from scratch — connecting borrowers to legal aid, nonprofit counselors, and state resources
- Created intake systems to capture borrower complaints and route them to the right organizations
- Built feedback loops so enforcement intelligence flowed back from frontline counselors to investigators
Significance
Turned the AG's enforcement presence into a two-way channel. Borrowers got help. The office got real-time intelligence about emerging harms that fed directly into subsequent investigations — including the Navient matter.
Rapid Response & Systems
Return to Repayment supervisory leadership
The problem
When the pandemic-era student loan payment pause ended, roughly 28 million borrowers were returning to repayment simultaneously — a policy transition with no historical precedent and enormous potential for servicer misconduct and consumer harm.
What we did
- Designed and led a real-time national supervisory initiative at the CFPB — before the transition began, not after problems surfaced
- Deployed multiple national investigative teams with coordinated rapid-response legal analysis protocols
- Built infrastructure to identify and address emerging harms as they appeared rather than months later through standard review cycles
- Secured substantial remediation for millions of borrowers during the transition period
Significance
An award-winning initiative that established a model for real-time consumer protection supervision during large-scale market transitions — applicable well beyond the student loan context.
Novel Legal Theory
Stopping pay-to-pay fees in auto and mortgage servicing
The problem
Servicers were charging borrowers $5–$15 simply to make a payment online or by phone — generating significant revenue while providing no meaningful service in return. The fees fell disproportionately on borrowers with the fewest alternatives and no obvious legal recourse.
What we did
- Identified pay-to-pay fees as an emerging enforcement target before they appeared on most regulators' radar
- Developed a novel UDAAP theory that pay-to-pay fees were unfair and abusive under Dodd-Frank — a theory not previously applied to this context
- Led citations against auto and mortgage servicers, creating a documented enforcement record
- Drafted industry guidance on behalf of the CFPB to put the market on notice
Significance
Established a replicable legal framework for challenging junk fees in financial services that regulators and advocates have since applied across multiple markets — including the school lunch fee work.
For the problems I'm tracking now — AI and consumer protection, the next generation of junk fee enforcement, market fairness — see Ideas & Ongoing Work.
Ideas & Ongoing Work →
If you want to take a novel, brave, but smart approach to a problem others have given up on — let's talk.
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