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Desktop Image: Kost, Thomas
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Thomas C. Kost

Partner

T 206.757.8357 Seattle
T 202.973.4200 Washington, D.C.
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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.

Practice Highlights

Investigations and enforcement

Develops and executes optimal client-specific strategies for defending government investigations and potential enforcement actions. Narrows and responds to administrative subpoenas and civil investigative demands (CIDs); prepares for and defends investigational hearings; drafts written responses to notices of potential law violations (NORA); and negotiates consent orders. Conducts internal investigations and leads clients through consumer remediation efforts and self-reporting to regulators when appropriate.

Examinations and licensing

Helps manage all aspects of supervisory relationships. Prepares clients for exams, including by evaluating policies and enhancing enterprise compliance management systems. Advises on best practices for interfacing with examiners during exams. Drafts responses to exam reports and PARR letters. Addresses potential state licensing issues resulting from exams.

Effective compliance strategies

Provides quick, practical advice on novel regulatory issues across the product lifecycle—with a keen appreciation of risk profile and business opportunity. Conducts proactive marketing and advertising reviews. Advises on best practices for deploying AI/ML tools to improve product offerings and customer experience. Brings deep knowledge of consumer financial laws (ECOA, TILA, FDCPA, FCRA, EFTA, GLBA) and the growing number of state commercial financing disclosure laws (CFDLs).
*Denotes an attorney's experience prior to joining Davis Wright Tremaine
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Admitted to Practice

  • District of Columbia, 2015
  • Washington, 2024
  • U.S. Court of Appeals, 4th Circuit
  • U.S. Court of Appeals, 6th Circuit
  • U.S. Court of Appeals, 9th Circuit
  • U.S. Court of Appeals, D.C. Circuit
  • U.S. District Court, Eastern District of Virginia

Education

  • J.D., Northwestern University Pritzker School of Law, 2012
    • Order of the Coif
    • Senior Online Editor, Northwestern University Law Review
  • B.A., Politics, Whitman College, 2007
    • Walter Brattain Scholar
    • Varsity Baseball

Memberships & Affiliations

    • Section Leader of the Antitrust, Consumer Protection, & Unfair Practices Section, Washington State Bar Association, 2024-present

Professional Recognition

    • Named "One to Watch" by Best Lawyers in Banking and Finance Law, 2024-2025

Background

    • Staff Attorney, Federal Trade Commission, Bureau of Consumer Protection, Division of Financial Practices, Washington, D.C., 2018-2021
    • Associate, Wilmer Cutler Pickering Hale and Dorr LLP, Washington, D.C., 2014-2018
    • Law Clerk, Hon. Leonie M. Brinkema, U.S. District Court, Eastern District of Virginia, Alexandria, Va., 2013-2014
    • Law Clerk, Hon. R. Guy Cole, Jr., U.S. Court of Appeals, 6th Circuit, Columbus, Ohio, 2012-2013
    • Summer Law Intern, U.S. Department of Justice, Civil Division, Federal Programs Branch, Washington, D.C., 2011
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