Amy L. Hanna Keeney, CIPP/US, is the firm’s Financial Services Regulatory and Compliance Team Leader. She has extensive experience helping banks, credit unions, and non-bank financial service providers of all sizes launch and service new financial products, and she helps them navigate the increasingly complex regulatory landscape for fintech services and products.
Additionally, Amy is a Certified Information Privacy Professional (CIPP) and has an in-depth understanding of financial privacy rights and how those rights impact a financial institution or service provider’s third-party risk management program. Amy frequently assists financial institutions and service providers with assessing the potential regulatory risk created by a new product or service.
Amy also has extensive experience counseling financial institutions and service providers regarding compliance with federal and state consumer protection statutes and regulations, including the Truth in Lending Act (TILA), the Equal Credit Opportunity Act (ECOA), and the Fair Credit Reporting Act (FCRA).
Amy is a Young Lawyer Liaison with the American Bar Association Fair Access to Services Subcommittee. The group is a subcommittee of ABA's Consumer Financial Services Committee, a professional development and relationship building forum that interacts with regulators, consumer advocates, and industry attorneys, and discusses best practices and emerging trends that are affecting all players in the consumer financial services industry.
Amy is the Pro Bono Chair of the firm’s Atlanta office and a proud supporter of the Atlanta Volunteer Lawyers Foundation. In her spare time, Amy is an avid home cook.
Education
Bar Admissions
Court Admissions
Areas of Practice
Acknowledgements
- Leadership Council on Legal Diversity Fellow, 2024
- Georgia Rising Stars® (by Thomson Reuters) Consumer Law, Technology Transactions 2017-2024
- Florida Law Review, Executive Editor
Professional Affiliations & Memberships
- American Bar Association, Fair Access to Services Subcommittee - Young Lawyer Liaison
- ANSI-accredited Certified Information Privacy Professional (CIPP/US)
- Thomson Reuters’ NextGen Leadership: Advancing Lawyers of Color, Advisory Board
Leadership Institute for Women of Color Attorneys (IWOCA), CLE Committee - Atlanta Volunteer Lawyers Foundation
- Atlanta Bar Association
- Florida Bar Association
Related Knowledge
News
Financial Services Regulation and Compliance
- Assisted several financial institutions with risk assessment and due diligence related to new consumer products and services, relationships with fintechs, and providing Banking-as-a-Service
- Created and assisted with implementation of financial institution’s third-party vendor management policy
- Assisted financial services provider with efforts to bring in-person application process online
- Assisted financial services startup with assessment of risk exposure related to expanding business throughout U.S.
- Assisted financial services startup with recommendations related to state licensure throughout U.S.
- Served as outside consumer regulatory counsel for several financial institutions and service providers and provided real-time counsel regarding various operational issues involving federal consumer financial protection regulations
- Created and assisted with implementation of financial institution’s enterprise-wide data retention policy
- Assisted financial institution with comprehensive revamp of its consumer dispute processing platform, including detailed review of dispute processing policies pursuant to the Fair Credit Reporting Act (FCRA), Real Estate Settlement Procedures Act (RESPA), Regulation X, Regulation Z, and Regulation E
- Assisted financial services provider with review and revamp of its Anti-Money Laundering and Office of Foreign Assets Control (OFAC) policy
Privacy
- Reviewed several financial institutions’ standard initial and annual privacy notices for compliance with the Gramm-Leach-Bliley Act and state financial privacy statutes
- Counseled financial services provider during its efforts to stand up a text and email notification program that is compliant with federal and state privacy statutes
- Revamped financial institution’s policy regarding release of financial data pursuant to federal Right to Financial Privacy Act and created forms for implementation thereof
- Assisted financial services provider with efforts to revamp its information security program to address FTC Safeguards Rule
Information Management
- Assisted financial services provider with comprehensive audit of its credit reporting and credit reporting dispute processing policies and practices
- Guided national tech company through acquisition of startup app platform geared toward acquiring child data and assisted client with analysis of application of Children’s Online Privacy Protection Act (COPPA) and The COPPA Rule to data acquired by acquisition
Data Breach Response
- Counseled several organizations of varying sizes through data breach incidents, including incident analysis and breach containment, incident disclosure (i.e., notification in compliance with all regulatory requirements), loss mitigation and remediation
Financial Services Litigation
- Successfully voided a three-year-old $300,000 default judgment obtained by consumer against a national mortgage servicing client in South Georgia
- Successfully defended a national mortgage lender in a lawsuit involving an erroneous legal description within a valuable REO parcel's chain of title by obtaining summary judgment in lender's favor on negligence, gross negligence, and unfair business practices claims
- Successfully defended a national bank against a consumer's FCRA claim by obtaining summary judgment in bank's favor and addressing issue of first impression in the U.S. Court of Appeals for the Eleventh Circuit
- Successfully defended national indirect auto lender against tort claim brought by consumer arising out of lender's alleged violation of automatic stay
- "The Open Banking Revolution: Section 1033's Mandate Requires New Technology and Agreements by Financial Institutions," published by Thomson Reuters Westlaw Today, August 2024
- "FDIC Sends Clear Message in Recent Enforcement Action: BaaS/Fintech Partnerships are a High-Risk Compliance Area," Adams and Reese Financial Services News Alert, December 2023
- "OCC Publishes Revised Examination Procedures Addressing Telephone Consumer Protection Act," published in Daily Business Review, ALM/Law.com, November 2023
- "Commercial Lenders: Are You Getting ready for the CFPB?" published in Westlaw Today/Thomson Reuters, April 2023
- "Much Ado About Nothing: Hunstein's Three Trips to the Eleventh Circuit Did Not Clarify Whether the FDCPA is a Financial Privacy Statute," Adams and Reese Financial Services News Alert, November 2022
- "Critical Infrastructure Providers Face New Cybersecurity Reporting Requirements," Adams and Reese Cybersecurity News Alert, March 2022
- "CFPB Solicits Feedback on Junk Fees - Are New Regulations Coming?" Adams and Reese Financial Services News Alert, February 2022
- "Notice Anything Different? Federal Regulators Issue Final Rule Setting New Computer Security Incident Notification Requirements for Banks and Service Providers," Adams and Reese Financial Services/Cybersecurity News Alert, November 2021
- "Payment Service Providers' Valuable Data is Getting More Regulatory Attention," Adams and Reese Financial Services News Alert, October 2021
- "Commercial Lenders: Are You Ready to Start Providing Data on Small Business Lending to the CFPB?" Adams and Reese Financial Services News Alert, September 2021
- "CFPB's New-and-Improved Reg F Provides Opportunities for Lenders to Protect Down-The-Line Debt Purchasers," Adams and Reese Financial Services News Alert, May 2021
- "Eleventh Circuit Renews the FDCPA as a Consumer Privacy Statute; Deals Major Blow to Debt Collection Services Industry," Adams and Reese Financial Services News Alert, April 2021
- "Regulatory Alphabet for Collections Compliance," Florida Bankers Association, April 2021
- Federal regulations involving consumer protection, including the FDCPA, TCPA, UDAP/UDAAP, FCRA, and UCC
- "Consumer Privacy and Community Banks: What You Need to Know," ICBA Conference, August 2020
- "CFPB Clarifies Abusiveness Standard in an Olive Branch to Financial Services Providers," Adams and Reese Financial Services Alert, January 2020
- "The Real Costs and Lasting Effects of a Data Breach and How to Limit Them," Lorman Webinar, January 2020
- "Complying with the California Consumer Privacy Act (CCPA) for Banks," Lorman Webinar, December 2019
- "Tales from the Front Lines of the Cyber War: Incident Response Best Practices and Breach Notification Requirements for the State of Florida, CCPA and the GDPR," CLE, Adams and Reese and the ACC Tampa Bay Chapter, December 2019
- "Stay Woke: Navigating the Ever-Changing Regulatory Environment," Panelist, Leadership Institute for Women of Color Attorneys, Inc. Conference, March 2019
- "Ask-a-Mentor,"
Next Gen Leadership: Advancing Lawyers of Color initiative, March 2019 - "CFPB Regulatory Guidance, UDAAP Enforcement Actions, and CFPB Hot Topics," Verminder's Thought Leadership Series Podcast. July 2018
- "CFPB Provides Some Relief to Mortgage Services Communicating with Borrowers, But Questions Remain," Adams and Reese Financial Services News Alert, March 2018