Jennifer M. Keas


Jennifer M. Keas is a partner and consumer financial services lawyer with Foley & Lardner LLP, where she litigates complex, high-stakes cases and other lawsuits and defends clients in investigations and proceedings initiated by the Consumer Financial Protection Bureau, as well as other matters involving regulatory agencies or state attorneys general.

Jennifer regularly provides clients with regulatory and compliance advice on issues arising under the Real Estate Settlement Procedures Act (RESPA), the Truth in Lending Act, and other federal and state consumer financial services laws. This includes proactively helping to find legal solutions for challenging business problems and counseling clients on matters such as:

  • consumer contracts and disclosures
  • business arrangements under RESPA, including marketing and advertising relationships and the establishment of affiliated business arrangements and joint ventures
  • fees, pricing, and new financial products or services
  • loan originator compensation
  • ability-to-repay and qualified mortgage requirements
  • mortgage marketing and advertising practices
  • issues relating to consumer privacy, data security, and document retention
  • fair housing and fair lending
  • management of risk posed by class actions and potentially unfair, deceptive, or abusive acts or practices
  • compliance review and development of compliance policies and procedures

As an experienced litigator and trial attorney, her diverse practice includes class action defense, RESPA litigation, defense of claims under unfair trade practice and consumer protection laws, environmental litigation, cases involving complex electronic discovery, appellate matters, issues affecting proprietary post-secondary schools, and other corporate defense work.


Awards and Recognition

Jennifer was selected for inclusion in the 2014 2016 Washington, D.C. Super Lawyers – Rising Stars® lists for her work in business litigation.

Community Involvement

In addition to her legal work with the firm, Jennifer is committed to pro bono work and charitable work. She is a member of Foley’s Charity Committee for the D.C. office.

Presentations and Publications

  • Presenter, “CFPB’s Prospect Consent Order – What Does it Mean to You and Your Real Estate and Title Partners” (February 2017)
  • Presenter, “Responding to Government Investigations, (May 2015)”
  • Presenter, “CFPB Enforcement Update: Takeaways and Future Areas of Focus,” (February 2014)

Thought Leadership

Jennifer is a frequent writer and speaker on topics of significance to the residential real estate and consumer finance industries, including as a contributor to the Consumer Class Defense Counsel (, a blog devoted to significant news and developments in the consumer financial services arena, and various publications for the Real Estate Services Providers Council, Inc. (RESPRO).

She has also assisted in the development and preparation of amicus briefs to inform the U.S. Supreme Court and federal appellate courts about how their decisions will affect businesses.

Firm Leadership

Jennifer serves as a hiring partner on the firm’s Recruiting Committee, where she is committed to recruiting talented and diverse attorneys to succeed at the firm.

12 April 2024 Honors and Awards

Jennifer Keas Named an Emerging Women Leader in Private Practice by DCA Live

Foley & Lardner LLP partner Jennifer Keas is named to DCA Live’s 2024 Emerging Women Leaders in Private Practice list.
23 February 2023 Article

CFPB Brings RESPA Reminder To Mortgage Comparison Sites

The Consumer Financial Protection Bureau ended a more than decadelong hiatus since the last formal guidance regarding Section 8 of the Real Estate Settlement Procedures Act on Feb. 7 by issuing its advisory opinion aimed at referral activity relating to mortgage comparison websites.
10 February 2023 Consumer Class Defense Counsel

Pay-to-Play in the CFPB’s Cross-Hairs: Digital Mortgage Comparison-Shopping Platforms under RESPA Scrutiny

The CFPB ended a more than decade-long hiatus since the last formal guidance regarding Section 8 of the Real Estate Settlement Procedures Act on February 7, 2023, by issuing its advisory opinion aimed at referral activity relating to mortgage comparison websites.
04 January 2022 Blogs

Federal Court Reads Between the Lines To Allow Unusual RESPA Section 8 Claim To Move Forward

We examine a recent court decision under Section 8 of RESPA and how the court read the complaint between the lines to allow the case to survive despite reasonable challenges by the defense for failure to state a claim.
09 July 2020 Blogs

Second Circuit Says Post-Litigation Notice of Arbitration Clause Sufficient to Bind Plaintiff

In a putative class action against Amazon, Nicosia v., Inc., the Second Circuit recently issued a ruling (“Nicosia II”) sending the named plaintiff’s claims to arbitration based on an arbitration clause contained in Amazon’s conditions of use.
23 March 2020 Blogs

Fourth Circuit Applies Spokeo to Bar RESPA Section 8 Class Action Claim

Late last week, the Fourth Circuit Court of Appeals rejected plaintiffs’ claim in a class action under Section 8 of the Real Estate Settlement Procedures Act (RESPA), which imposes a broad prohibition against referral fees or kickbacks in the real estate settlement context.