$9.5B CFPB Enforcement Trio Targets Abusive Finance

Three former CFPB enforcement leaders who helped secure orders for $9.5 billion in penalties and consumer payments have launched a public interest law firm aimed at financial and civil rights abuses.

Eric Halperin, Cara Petersen and Tara Mikkilineni are founding partners of Halperin Petersen & Mikkilineni LLP, or HPM, a new firm focused on consumer rights, tenant rights, workers’ rights and civil rights, according to PYMNTS. The launch moves three former senior government enforcers into private public interest litigation at a politically charged moment for consumer finance oversight.

The firm said it will target practices including predatory lending, illegal junk fees, deceptive schemes, unlawful evictions, discriminatory housing practices, wage theft, illegal misclassification, invasive monitoring programs, algorithmic wage-setting and discriminatory lending, according to a Tuesday, July 14, HPM press release.

“We believe litigation is critical to pushing back against corporate abuse,” Halperin said in the release.

Former CFPB enforcement leaders launch public interest law firm targeting financial abuses

The core fact is the track record. Between 2021 and 2025, Halperin, Petersen and Mikkilineni led a Consumer Financial Protection Bureau team that secured orders for $9.5 billion in penalties and payments to consumers, according to HPM’s release.

That number now frames the new CFPB enforcement law firm. HPM is not pitching itself as a narrow consumer finance boutique. Its stated agenda links finance, housing, work and civil rights under one umbrella of alleged economic abuse.

The founders’ CFPB roles give the firm unusual enforcement experience for private public interest litigation. Halperin was enforcement director at the CFPB from 2021 to 2025, according to Protect Borrowers’ November 2025 announcement. Petersen served in senior CFPB roles, including Principal Deputy Enforcement Director from 2018 to 2025. Mikkilineni was a senior adviser to CFPB Enforcement leadership.

The move follows a period of visible departures from the bureau. PYMNTS reported in June 2025 that Petersen resigned as acting enforcement director and said CFPB leadership under President Donald Trump “has no intention to enforce the law in any meaningful way.” Bloomberg reported Tuesday that Halperin and Mikkilineni also left the CFPB shortly after Trump began his second term.

Analysis: HPM’s formation shows enforcement talent moving outside the federal chain of command. That doesn’t mean private litigation can replace government enforcement. It does mean companies accused of abusive practices may face lawyers who know how federal enforcement teams build cases.

CFPB veterans bring a federal playbook to consumer, tenant and worker cases

HPM’s target list is broad by design. It reaches beyond classic consumer finance into rent, labor classification, workplace surveillance and AI-linked pay practices.

Algorithmic wage-setting is one of the more technical items on the list. In plain terms, it refers to software systems that help set or recommend wages, compensation or pay-related terms. Mikkilineni told Bloomberg that technology-powered financial abuses will be among the firm’s areas of focus.

“We saw old school predatory financial models morph into a particular set of technologies, and I think they’re going to go through another morphing now that AI can make all of that more powerful, more seamless, and frankly less transparent to the consumer,” Mikkilineni said. “It seems unlikely that the federal government will be doing a lot of intervention in that area.”

That quote points to the clearest technology angle in the HPM launch. The firm is not only looking at fees and lending. It is explicitly flagging AI-enabled or software-mediated practices that may make abusive conduct harder for consumers or workers to see.

XOOMAR has tracked similar concerns in other AI-heavy markets, including the governance fight covered in OpenAI Safety Resignation Exposes Model Risk Fight. The connection is not that these stories involve the same companies or claims. It is that both turn on accountability when automated systems shape high-stakes decisions.

HPM’s stated scope also overlaps with fintech and payments risk. Illegal junk fees, deceptive schemes and discriminatory lending sit close to the same compliance pressure points that appear in payment operations, commerce platforms and embedded finance. For more on how payments infrastructure is consolidating inside business software, see our coverage of PayPal pulling payment sprawl inside Adobe Commerce Admin.

Analysis: The firm’s public positioning suggests a broad theory of economic harm. HPM appears likely to treat finance, housing and work as connected arenas where companies can extract money or restrict opportunity. That is an interpretation of the firm’s stated issue list, not a claim about any case it has filed.

Companies facing consumer protection scrutiny should watch HPM’s first cases

The next signal will come from HPM’s first filings, if and when they arrive. The named targets in the launch materials are categories, not defendants.

That matters. A complaint against a lender over fees would say one thing about the firm’s priorities. A case over workplace monitoring or algorithmic wage-setting would say something different. A housing discrimination case would push the firm’s early identity even further from a traditional consumer finance lane.

Before forming HPM, the same three lawyers joined Protect Borrowers as senior fellows in November 2025 to launch a strategic enforcement project focused on corporate power and financial crisis among working people. Protect Borrowers said that project would use legal and policy tools and work with private firms, state and local law enforcers, and advocacy organizations.

HPM’s own release now places the lawyers inside a law firm structure. The source material does not say which plaintiffs, partners or defendants will be involved. It also does not say whether the firm will prioritize class actions, impact litigation, referrals to regulators or negotiated resolutions.

The open question for financial firms, landlords, employers and tech-enabled service providers is narrower and more practical: which practices will HPM test first in court?

Companies in the firm’s stated zones of interest should watch for four signals:

• First defendants: Whether HPM starts with financial institutions, housing operators, employers or technology-linked platforms.
• First legal theories: Whether the early cases lean on consumer protection, civil rights, tenant rights or worker rights claims.
• AI angle: Whether algorithmic wage-setting and invasive monitoring appear early or remain longer-term priorities.
• Partner strategy: Whether HPM works alongside advocacy groups, state or local enforcers, or other plaintiffs’ firms.

Even if federal priorities shift, legal risk does not disappear. HPM’s launch shows that former CFPB enforcement leaders are taking their playbook into private public interest litigation. The first cases will reveal how sharp that playbook looks outside government.

Disclaimer: This XOOMAR analysis is for informational and educational purposes only. It is not financial, investment, legal, tax, or professional advice. It does not provide buy, sell, hold, price-target, portfolio, or personalized recommendations. Verify information independently and consult qualified professionals before making decisions.

Impact Analysis

• The firm brings former CFPB enforcement experience into private public interest litigation.
• Its agenda targets financial, housing, labor and civil rights abuses under one litigation strategy.
• The launch comes as consumer finance oversight remains politically contested.