Joseph "Joe" Reilly

Joseph “Joe” Reilly advises a wide variety of financial services companies as they navigate increasingly complex regulatory and compliance requirements.

He regularly represents lenders, fintech startups, neobanks, and mortgage servicers in enforcement matters, including informal investigations and examinations by the Consumer Financial Protection Bureau (CFPB), OCC, Federal Reserve, FDIC, SEC, numerous state agencies, and the mortgage government-sponsored enterprises such as Fannie Mae. His compliance counseling work covers the entire range of consumer and business lending laws and rules under TILA/Reg. Z, ECOA/Reg. B, UDAAP, EFTA/Reg. E, the Fair Credit Reporting Act, debt-collection laws, GLBA privacy provisions, state licensing regimes, and others.

Joe also advises financial services providers on all aspects of BSA/AML compliance, and has litigated SAR confidentiality and immunity provisions.

Joe has extensive experience advising on mortgage law matters, including RESPA’s anti-kickback provisions, and fair lending, servicing, and mortgage insurance issues. He is the principal author of CFPB Mortgage Origination Rules Deskbook published by the American Bankers Association. The 625-page treatise, now in its 2nd edition, is the definitive guide to the CFPB’s mortgage origination rules mandated by the Dodd-Frank Act.

For banks and bank-affiliated clients, Joe advises on bank powers, federal preemption, and a variety of Bank Holding Company Act matters. He also advises credit unions and Farm Credit lenders on compliance issues across the range of their lending and investing activities.

Prior to law school, Joe served for four years as a professional staff member on the U.S. House of Representatives’ Financial Services Committee, rising to the post of chief investigator for its Democratic members.

• Advising banks and nonbank mortgage originators and servicers on all key CFPB mortgage rules, including TRID, loan-originator compensation, QM, servicing, foreclosure, and SAFE Act registration and licensing.
• Counseled multiple clients regarding the expansion of business into FinCEN-regulated MSB activities.
• Represented a fintech bank in litigation over SAR confidentiality and immunity provisions.
• Counseled a technology services provider in design of a loan-application procedure compliant with CIP and beneficial-ownership requirements.
• Advised one of the leading marketplace-lending banks in the U.S. in regulatory due diligence of potential nonbank partners and on partner marketing campaigns.
• Advised more than a dozen clients on the new TILA-like commercial financing disclosure requirements in California, Utah, Virginia, and New York.
• Drafted comment letter on behalf of major trade association on the CFPB’s Small Business Lending Data Collection proposed rule (implementing Dodd-Frank Act § 1071.)
• Advised bank partners on state-law licensing in marketplace lending transactions.
• Advised multiple banks on issues of bank powers, preemption, control, and affiliate transactions.
• Represented VyStar Credit Union on its regulatory applications for largest-ever proposed bank acquisition by a credit union.

• Member, American College of Consumer Financial Services Lawyers