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Sarah Auchterlonie

Brownstein Hyatt Farber Schreck LLP

ShareholderDenver, CO
Consumer Financial ServicesDenver, CO

Recognized for

Consumer Financial Services

The Elite Counsel Perspective

Banks and consumer finance companies benefit from Sarah’s exceptional judgment, shaped by decades of government regulatory service and work on products, investigations and transactions.

Banks and consumer finance companies benefit from Sarah’s exceptional judgment, shaped by decades of government regulatory service and work on products, investigations and transactions.

— Elite Counsel
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Overview

Sarah Auchterlonie advises consumer finance companies and banks on regulation, transactions and consumer products. As chair of Brownstein Hyatt Farber Schreck’s Consumer Protection Group, she works with clients to align transactions and product offerings with their compliance, effectiveness and growth goals. Her practice spans investigations, licensing, investments, financing, mergers and acquisitions, as well as the development of contracts, policies and procedures.

Sarah’s consumer financial services work draws on decades of government bank regulatory service and experience with federal and state financial services and antitrust regulators. She advocates for clients before Congress and federal and state agencies. In litigation, she has tried and resolved matters in administrative, federal and state venues, and she provides expert testimony on consumer finance topics. Her background in data science, economics and finance also informs her advice to companies operating in complex financial markets.

Sarah serves on the Colorado Banking Board, which supervises Colorado-chartered banks, trusts and money transmitters. She previously worked as a trial attorney in Washington, D.C., with the U.S. Department of the Treasury’s Office of Thrift Supervision during the financial crisis. She later became an acting deputy enforcement director and one of the founding employees of the Consumer Financial Protection Bureau. She is also co-author of the BNA treatise Consumer Finance Law and Compliance.

Representative Experience

  • 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.

Education

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

Admissions

  • Colorado
  • Washington, D.C.
  • U.S. Court of Appeals, D.C.
  • U.S. Court of Appeals, Fourth Circuit
  • U.S. Court of Appeals, Tenth Circuit
  • U.S. Court of Appeals, Eleventh Circuit
  • U.S. District Court, District of Colorado
  • U.S. District Court, Eastern District of Missouri
  • U.S. District Court, Southern District of Texas

Honors & Recognition

  • “Sarah’s an encyclopedia on consumer finance.”– Chambers USA, 2025
  • “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
  • 5280 Top Lawyers, 2025-2026
  • The Best Lawyers in America, 2021-2027
  • Chambers USA, 2023-2026

Professional Associations

  • Board of Directors, Habitat for Humanity of Metro Denver
  • Board Chair, 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 America

Publications

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