Practice Chair
Sarah Auchterlonie

Sarah Auchterlonie



Authority on consumer finance regulation and law. Decades of government bank regulatory service. Develops multidisciplinary solutions for consumer finance companies and banks. 

As chair of the firm’s Consumer Protection Group and with deep understanding of consumer finance law and markets, Sarah Auchterlonie ensures that transactions and consumer product offerings achieve her clients’ compliance, effectiveness and growth goals. As an advocate in Congress or with federal and state agencies, she brings decades of experience working with federal and state financial services and antitrust regulators. In litigation, Sarah has successfully tried and resolved cases in administrative, federal and state venues, and also provides expert testimony on consumer finance topics. Her strong technical skills in data science, economics and finance uniquely suit her to advising cutting-edge companies in complex financial markets. Whether she is developing contracts, policies and procedures, or advising consumer finance companies in investigations, licensing, investments, financing or mergers and acquisitions, Sarah brings creativity and a lexicon of consumer finance legal knowledge to bear for her clients.

A respected thought leader on consumer finance and banking, Sarah sits on the Colorado Banking Board, the supervisory authority over Colorado-chartered banks, trusts and money transmitters. She is also the co-author of the legal treatise, Consumer Finance Law and Compliance, published by BNA. Previously, she was a trial attorney with the U.S. Department of the Treasury’s Office of Thrift Supervision in Washington, D.C. during the financial crisis and an acting deputy enforcement director and one of the founding employees of the Consumer Financial Protection Bureau (CFPB).

Representative Matters

Government Investigations

  • Advised  a regional retailer in a matter with the Colorado Attorney General's Uniform Consumer Credit Code Administrator in an investigation regarding its "house account" loans and another retailer with regard to installation practices and insurance. In both instances, the UCCC Administrator closed the examinations after she agreed that the practices in question complied with the Code and applicable federal law.

  • Advise a cryptocurrency trading and portfolio management platform in its licensing, compliance management, examinations and regulatory inquiries with issues involving securities, BSA/AML, money transmissions, and consumer protection.

  • Advised a nationwide debt buyer in a matter with the Consumer Financial Protection Bureau that resulted in a consent order related to the debt collection activities of third party agencies. We advocated that the client’s own collection practices were compliant and that its past third party oversight failures were due a former executive. In addition, we advise several other firms in the mortgage, credit rehabilitation, home renovation loan, and debt collection industries on investigations and regulatory relations with the Consumer Financial Protection Bureau.


  • Enhanced operational efficiency for a lender and fiduciary loan servicer in the real estate market to streamline policies and procedures related to consumer privacy, attorney-represented debtors, and debt settlement and credit repair organizations (CROA). The end product is a detailed policy and procedure portfolio to ensure compliant and effective handling of past-due accounts.

  • Counsel to Restore, a fintech startup that helps consumers with defaulted debt pay-off old accounts through loyalty shopping rewards. Advising the client from inception through launch, we guided the founders through the maze of FDCPA, FCRA, GLBA and state law requirements to build the operations functions and compliance program for Restore.

  • Act as outside financial services regulator for federally-recognized American Indian Tribes. Sarah and her team stand-up regulatory commissions with similar supervision and enforcement authorities as the CFPB and state departments of finance. This work ensures that tribal lender consumers receive the same regulatory protections as state-licensed lenders and that tribal governments exercise control and direction of their economic development projects.


  • Negotiate agreements and provide advisory services for online casino and sports betting applications related to payment processor agreements and transacting with consumers in electronic commerce.

  • Counsel to a major online financial services referral website in transaction due diligence with respect to its acquisition of a credit repair and advisory business. We reviewed the transaction for contract compliance; drafted specific agreement provisions to protect the buyer in the event of a data breach or failures in PCI compliance; and ensured that the acquisition target was properly licensed and had all necessary state approvals to close the deal.

  • Counsel to a market-leading home renovation loan financial services firm in the expansion of its product offerings and licensing. We support company executives through all stages of product development, including licensing, drafting consumer agreements and disclosures, negotiating with vendors, developing policies and procedures, and employee training and oversight. We help our clients grow by designing for compliance.

  • Advise multiple firms in the residential real estate industry concerning compliant agreements and relationships under the Real Estate Settlement Procedures Act and state and federal consumer financial protection laws.

Insights & Publications



  • J.D., 2002, Washington University in St. Louis School of Law
  • B.L.S., 1998, University of South Dakota, Phi Beta Kappa


  • Washington, D.C.
  • Colorado

Community Involvement


Board of Directors, Habitat for Humanity of Metro Denver

Public Member, Board of Directors, Colorado State Banking Board

Former Adjunct Professor, Sturm College of Law, University of Denver

Former Cub Scout Den Leader, Boy Scouts of AmericaAdmissions



"Sarah is knowledgeable, thorough and professional in every interaction." "Sarah is an excellent practitioner and extremely detailed." - Chambers USA, 2024

“Sarah is really great to work with; she's very knowledgeable, responsive and pragmatic." “Sarah Auchterlonie is extremely knowledgeable. She provides options where applicable, always listing the associated risk, if any. She's a forward thinker, understanding our industry and future potential issues." - Chambers USA, 2023

Best Lawyers in America, 2021-2024

Chambers USA, 2023-2024