Eamonn K. Moran

Previously, Eamonn served as counsel in the Office of Regulations at the CFPB. He served as part of a number of rulemakings affecting the consumer financial services industry including the Ability-to-Repay/Qualified Mortgage Rule under the Truth in Lending Act (TILA) (Regulation Z) and Integrated Mortgage Disclosures Rule under the Real Estate Settlement Procedures Act (RESPA) and TILA (Regulations X and Z). Eamonn also provided the public with guidance on the CFPB's regulations including RESPA, TILA Open-End (Regulation Z), Electronic Fund Transfer Act (Regulation E), and Interstate Land Sales Act. He was also a member of the Bureau's Small Dollar Lending Working Group.

Prior to joining the CFPB, Eamonn served as a senior attorney advisor at the US Department of the Treasury, where he worked in the Office of the Special Inspector General for the Troubled Asset Relief Program. During his time at the Treasury, he drafted significant sections of quarterly reports for Congress, drafted congressional testimony, and focused on the rescues of AIG, General Motors, Chrysler, and Ally Financial (formerly GMAC) among other TARP investments. Eamonn also advised his office on the implementation of the Dodd-Frank Act with respect to mortgage servicers, financial institution designations and regulation, capital requirements, and capital market activities.

Before joining the Treasury, Eamonn was a counsel for the Congressional Oversight Panel for the Troubled Asset Relief Program, an independent panel within the United States Senate which was chaired by now Senator Elizabeth Warren and charged with reviewing the state of financial markets in conjunction with the oversight of TARP pursuant to the Emergency Economic Stabilization Act of 2008. While there, he investigated all aspects of the Treasury's TARP actions including the legality of its use of funds and the impact of TARP on financial institutions and markets.

Eamonn began his career as a finance/real estate associate at a New York City law firm and as a research associate at the Center for Banking and Finance at the University of North Carolina School of Law where he conducted extensive legal research and wrote legal memoranda relating to government investment in banks. 

• Represented a “disruptor” banking services provider in a state regulatory inquiry.
• Conducted regulatory due diligence on a number of regional and national consumer financial services providers on behalf of investors, including assessing compliance with US state and federal licensing requirements for marketplace lenders, mortgage lenders, auto lenders, payments intermediaries, student lenders, and debt collectors.
• Advised online P2P businesses on US federal and state money services licensing and anti-money laundering requirements.
• Advised a provider of gift card and consumer loyalty programs on regulatory compliance issues, including escheatment obligations.
• Advised clients on regulatory matters regarding debt-collection practices involving consumer credit products, including credit cards, student and auto loans, deposit accounts, and unsecured lines of credit.
• Representation of companies in responding to state inquiries regarding unlicensed money transmission.
• Representation of numerous engagements to conduct due diligence of prospective money transmitter partners for established companies.
• Representation of applicants in various states for money transmitter licenses and FinCEN registration issues.
• Representation of many retailers and program managers for gift card, gift transfer, stored value, and related prepaid products and services, including highly sophisticated reloadable products.
• Representation of nonbank fintech firms (e.g., payments intermediaries, online lenders, money transmitters, cryptocurrency providers and exchanges) on BSA/AML regulatory and compliance matters, including customer identification activities.
• Counseled a mortgage origination platform on implementation of the CFPB's final rule integrating mortgage origination disclosures under TILA and RESPA (sometimes referred to as the Bureau's TILA-RESPA Integrated Disclosure, or "TRID" rule, or the "Know Before You Owe" initiative).
• Counseled a federally chartered stock savings bank regarding its federal and state charter options, including analysis of the powers, limits, and authorities applicable to national banks and federal savings associations.
• Counseled a large retailer regarding its partnership with a financial institution to roll out a prepaid/checking account product available exclusively on the retailer’s shelves.
• Advised a large national bank in conducting a comprehensive review of its mortgage servicing transfer policies and procedures to ensure compliance with the CFPB’s mortgage servicing and asset ownership transfer rules. The review covered all aspects of compliance, including applicable rules, policies and procedures, risk assessment, issues management, and training.
• Assisted one of the largest non-bank mortgage servicers in identifying and implementing enhancements to its compliance risk management system and conducted similar reviews for a large non-bank mortgage originator and a non-bank originator and servicer of reverse mortgages.
• Advised a new platform on structuring its compliance management system to ensure compliance with the ability-to-repay/qualified mortgage rules, fair lending and other consumer financial protection laws in marketing loans to subprime borrowers.
• Led TILA and RESPA compliance policy reviews for major national banks, preeminent card issuers, large credit unions, mortgage servicers, and mortgage originators.
• Provided financial institutions and other interested parties with product reviews, including 
  for mobile payment and digital wallet services.
• Counseled a large financial institution with respect to the regulatory requirements pertaining to its account opening processes and procedures in different platforms, including in-branch, online, and mobile app.
• Represented entities in responding to CFPB civil investigative demands, including Petitions to Withdraw the CID.
• Advised a financial services provider in conducting a comprehensive review of its FCRA policies and procedures to ensure compliance with the FCRA and Regulation V requirements. The review covered all aspects of compliance, including applicable rules, policies and procedures, operations, risk assessment, issues management, governance, and training.