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Eamonn K. Moran

815 Connecticut Avenue, NW
Suite 620
Washington, District of Columbia 20006
Phone:  202.659.6709
Fax:  202.659.4130

Biography

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.

His clients include major national banks, preeminent card issuers, large credit unions, mortgage servicers, and mortgage originators. He has also handled matters for other financial services providers, including mobile payment and digital wallet services.

Previously, Mr. Moran served as counsel in the Office of Regulations at the CFPB. Mr. Moran 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). 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 focused 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 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, 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.

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 then U.S. Senator John E. Sununu.

Representative Experience

  • 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.

Speaking Engagements

  • "Exploring Special Purpose National Bank Charters for Fintech Companies," Fintech Webinar Series, May 2017
  • "Consumer Payments in 2017: Regulatory Developments and Prospects For Consumer Gift Cards, Prepaid Cards, and Other Consumer Electronic Payment Methods," Webinar, January 2017
  • "The CFPB’s Mortgage Servicing Rules and What They Inform Us About Potential Rules for Student Loan Servicing," Panelist, National Council of Higher Education Resources 2016 Winter Legal Meeting, February 2016
  • “A Review of the TILA-RESPA Integrated Disclosure Rule,” Webinar, February 2016
  • “Current Issues in Mortgage Origination and Servicing,” Webinar, March 2015

Published Works

  • "AI's Role In Financial Services: Some Early Lessons," Law360, November 2018
  • "The Growing Power of Fintech Lenders," BankDirector, October 2017
  • "Electronic Mortgage Closings Improve Homebuying," Law360, August 2017
  • "The CFPB’s Enforcement of the Prohibition on Abusive Acts and Practices," Co-Author, Bloomberg BNA Banking Report, February 2015
  • "Understanding and Applying Dodd-Frank’s ‘Abusive’ Standard," Co-Author, Bloomberg BNA Banking Report, January 2015
  • "The Uncertain Utility Of A CFPB No-Action Letter," Co-Author, Law 360, October 2014
  • "Wall Street Meets Main Street: Understanding the Financial Crisis," North Carolina Banking Institute, 2009

Legal Experience

  • LeClairRyan, Washington, D.C., 2019 - present
  • Kilpatrick Townsend, Washington, D.C., 2016 - 2019
  • WilmerHale, Washington, D.C., 2014 - 2016
  • Consumer Financial Protection Bureau, 2012 - 2014
  • United States Department of the Treasury, 2011 - 2012
  • United States Senate, 2009 - 2011
  • University of North Carolina, Center for Banking and Finance, 2008 - 2009
  • Thacher Proffitt & Wood, New York City, 2007 - 2008

Memberships and Affiliations

  • 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 Alumni Club of Metropolitan Washington, D.C., Secretary, 2011 - 2015
  • Georgetown University Alumni Association, Board of Governors, Member, 2014 - present
  • Hoya Hoop Club, Board of Directors, Member, 2013 - present

Distinctions

  • Washington, D.C. "Rising Star" for Consumer Law in the 2018 and the three immediately preceding editions of Super Lawyers magazine
  • JD Supra Readers' Choice Award, top author for Finance & Banking, 2018

Related Industries

Education

  • J.D., Georgetown University, 2007, Dean's Certificate
  • B.A., History and Government, magna cum laude, Georgetown University, 2004

Bar Admissions

  • District of Columbia, 2009
  • New York, 2008

Court Admissions

  • United States Supreme Court