Eamonn Moran has extensive experience handling matters in the financial services industry including those pertaining to consumer financial services, consumer protection, fair lending, TARP, the Dodd-Frank Act, and the Consumer Financial Protection Bureau (CFPB), where he previously served as counsel in the Office of Regulations.
Mr. Moran has particular experience in mortgage finance issues. He has conducted compliance reviews of several mortgage companies’ originations and servicing businesses. Mr. Moran also maintains an active practice in the areas of retail financial services and consumer protection. He advises clients on all federal and state regulatory compliance matters for banking and consumer financial services. Mr. Moran has provided strategic and technical advice on the rulemakings mandated by Dodd-Frank. He regularly advises consumer financial services clients on a wide variety of legal issues including the federal consumer financial protection laws – especially the Truth in Lending Act, Real Estate Settlement Procedures Act, Electronic Fund Transfer Act, Fair Credit Reporting Act, Truth in Savings Act, and Equal Credit Opportunity Act. Mr. Moran advises on implementation of the TILA-RESPA integrated disclosures, other residential mortgage compliance matters, and on a range of consumer financial products including credit cards, deposits, prepaid cards, payday and installment loans and private student loans. He also counsels clients on unfair, deceptive or abusive acts or practices (UDAAP) risk, and on investigations and enforcement actions by the CFPB and other federal and state agencies.
Prior to joining the firm, Mr. Moran was a senior associate and then counsel in the Washington, D.C. office of an international law firm where he was a member of its Consumer Financial Protection Bureau Working Group where his practice included consumer financial services, mortgage regulation, banking regulation, and financial services activities.
Previously, Mr. Moran served as counsel in the Office of Regulations at the Consumer Financial Protection Bureau (CFPB) which is responsible for researching and analyzing legal and policy issues, drafting proposed and final rules and providing guidance to CFPB leadership, and supervision and enforcement staff regarding consumer financial protection laws. While at the CFPB, Mr. Moran was a 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). He 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. Mr. Moran was also a member of the Bureau's Small Dollar Lending Working Group.
Prior to joining the CFPB, Mr. Moran served as a senior attorney advisor at the U.S. 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, Mr. Moran drafted significant sections of quarterly reports for Congress, drafted congressional testimony, and specialized on the rescues of AIG, General Motors, Chrysler, and Ally Financial (formerly GMAC) among other TARP investments. He 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, Mr. Moran was a counsel on the Congressional Oversight Panel for the Troubled Asset Relief Program, an independent panel 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, Mr. Moran 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. He specialized in certain TARP programs including the Capital Purchase Program, the Automotive Industry Financing Program (General Motors, Chrysler, Chrysler Financial and Ally Financial), the AIG rescue, and the additional assistance provided to Bank of America and Citigroup. Mr. Moran also assisted with preparing comprehensive monthly reports related to EESA ranging from mortgage modifications pursuant to the Home Affordable Modification Program, the use of TARP funds in support and reorganization of the domestic automotive industry, and the use of guarantees and contingent payments in TARP and other programs to the examination of credit markets and the Term Asset-Backed Securities Loan Facility. He also examined the execution of the banking “stress tests” and the international aspects of the financial crisis.
Mr. Moran 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.
While attending law school, Mr. Moran was a student attorney in the Appellate Litigation Clinic at Georgetown University Law Center, a law clerk in the Civil Division of the U.S. Department of Justice, and a judicial intern to the Honorable Marian Blank Horn in the U.S. Court of Federal Claims. During college, Mr. Moran served as an intern in the Washington, D.C. office of former U.S. Senator John E. Sununu.
Mr. Moran was recognized as a Washington, D.C. "Rising Star" for Consumer Law in the 2015, 2016, and 2017 editions of Super Lawyers magazine.
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.
Georgetown University Law Center, J.D. (2007) Dean's Certificate
Georgetown University, B.A., History and Government (2004) magna cum laude
District of Columbia (2009)
New York (2008)
U.S. Supreme Court
American Bar Association, Consumer Financial Services Committee, Member
American Bar Association, Banking Law Committee, Member
Hoyas Unlimited, Board of Directors, Member (2015-Present)
Georgetown Alumni Club of Metropolitan Washington, D.C., President (2015-Present)
Georgetown University Alumni Association, Board of Governors, Member (2014-Present)
Hoya Hoop Club, Board of Directors, Member (2013-Present)
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