Thomas C. Kost

Thomas represents financial services clients in high-stakes enforcement matters, supervisory examinations, and licensing disputes before federal and state regulatory agencies. Using insight earned as a former staff attorney with the FTC's Bureau of Consumer Protection, Thomas guides clients through every step of solving their toughest regulatory challenges, empowering clients to stay focused on achieving their business goals with minimal disruption.

Thomas has successfully defended banks, credit unions, fintechs, and other financial service providers facing scrutiny by the FTC, CFPB, state attorneys general, and prominent state financial regulators such as the California DFPI and New York DFS. He has frequently resolved these matters confidentially and on favorable terms, but when that's not possible, Thomas has extensive experience litigating for and against the government—having won on both sides. He's versed in the wide range of consumer protection laws enforced by regulators, including federal and state laws relating to unfair, deceptive, or abusive acts or practices (UDAAP), fair lending, consumer credit, debt collection, credit reporting, financial privacy, and small business financing.

Thomas's expertise spans the entire spectrum of consumer financial products and services—from payments to lending to deposits. In particular, he focuses on the use of cutting-edge technologies in financial services, especially artificial intelligence and machine learning (AI/ML), and how existing laws apply to those technologies. Clients turn to Thomas for his sound judgment in regulatory grey areas and his ability to explain the value of fintech innovations in a way that resonates with regulators.

Pro bono work is an important part of Thomas's practice. He has written amici briefs and completed several projects promoting financial inclusion and access to safe and affordable housing for members of underserved communities.