[6] Brooks's career includes working as Managing Partner of the Washington, D.C. office of the global law firm O’Melveny & Myers, where he led an office of more than 150 attorneys, represented major financial services companies in a variety of litigation and enforcement matters, and played a lead role in crafting the banking industry's response to the 2010–2011 foreclosure crisis.

In that position, he advised executive management and the board of directors on legal, risk, and strategic issues; developed and implemented strategies to manage litigation and government inquiries; led deal teams for strategic transactions; and led the bank's compliance with regulatory orders on mortgage servicing and foreclosures.

[8] From 2014 to 2018, Brooks served as Executive Vice President, General Counsel, and Corporate Secretary of the $3.2 trillion Fannie Mae.

In this role, he oversaw the Legal Department and Government and Industry Relations and served as a senior advisor to the Chief Executive Officer and the Board of Directors.

At Coinbase, he was responsible for the company's legal, compliance, internal audit, government relations, and global intelligence groups.

From November 2017 through March 2020 he served with former FDIC Chair Sheila Bair, former American Express CEO Jim Robinson, and others on the board of directors of Avant, Inc., a marketplace lending and technology platform company.

He was also an advisor to financial technology companies Spring Labs, a blockchain-enabled digital credit bureau, and EarnUp, a consumer loan payment platform.

[21] On May 20, 2020, the OCC, under Joseph Otting finalized a rule to strengthen and modernize regulations implementing the Community Reinvestment Act for national banks and savings associations.

[24] On July 22, 2020, the OCC, under Brooks' direction, published a letter clarifying national banks' and federal savings associations' authority to provide cryptocurrency custody services for customers.

"[25] On September 21, 2020, the OCC, under Brooks, issued a second letter regarding cryptocurrencies, which clarified national bank and savings association authority to hold deposits reserves backing stablecoins.

[29] Fintech startup SoFi also received conditional approval from the OCC for a de novo national bank charter during Brooks's tenure.

[37] On October 14, 2020, the OCC fined USAA Federal Savings Bank $85 million "for shortcomings in its risk management and compliance with laws protecting service members.

He has served as a board member of the California Bankers Association (vice chairman at large),[47] the Housing Policy Council (executive council), the Appleseed Foundation (chairman),[48] the National Symphony Orchestra (treasurer), the Los Angeles Master Chorale (treasurer),[49] the Blockchain Association, and the Pasadena Conservatory of Music.