• JD, Georgetown University Law Center, 2007
• BA, magna cum laude, Georgetown University, 2004

• District of Columbia Bar
• Maryland State Bar
• New York State Bar

Eamonn's recent experience includes:

• Advised a B2B BNPL provider concerning regulatory compliance and product structure.
• Provided counsel to a marketplace platform during the introduction of an international e-commerce payment solution.
• Provided counsel to an international company that operates in the mobility sector (i.e., parking solutions, public transportation, etc.) concerning money transmission licensing, money services business registration, and ways to structure the platform to mitigate regulatory risk.
• 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.   

• Co-Chair, The New York City Bar Association Task Force on Digital Technologies, Subcommittee on Digital Technologies Consumer Protection
• Rising Star - Consumer Law, Washington, DC, Super Lawyers, 2015–2021
• Top Author, Finance & Banking, JD Supra Readers' Choice Awards, 2018
• Recognized, Capital Pro Bono Honor Roll, 2018, 2020

• In the Media
• "NY Assembly bill counters governor on BNPL," Payments Dive, March 27, 2024 (Eamonn Moran quoted)
• "Banking industry takes legal action against US cap on late credit card fees," The Banker, March 8, 2024 (Eamonn Moran quoted)
• "CFPB hiring for tech enforcement," Payments Dive, January 31, 2024 (Eamonn Moran quoted)
• "NY may drive out BNPL firms: attorneys," Payments Dive, January 30, 2024 (Eamonn Moran quoted)
• "What New York Gov. Hochul's pressure on BNPL means for lenders," American Banker, January 4, 2024 (Eamonn Moran quoted)
• "NY governor pursues BNPL regulation," Payments Dive, January 3, 2024 (Eamonn Moran quoted)
• "Bank of America's overdraft fees targeted by regulators despite 86% YOY drop," S&P Global Market Intelligence, July 19, 2023 (Eamonn Moran quoted)
• "Will BNPL pass the test?," Payments Dive, June 27, 2023 (Eamonn Moran quoted)
• "Apple, Google Likely Targets in Consumer Watchdog Payments Rule," Bloomberg Law, June 26, 2023 (Eamonn Moran quoted)
• "CFPB codifies approach to abuse as it cracks down on banks," S&P Global Market Intelligence, April 11, 2023 (Eamonn Moran quoted)
• "Banks foresee compliance challenges as new CFPB loan reporting rules approach," S&P Global Market Intelligence, March 28, 2023 (Eamonn Moran quoted)
• "Supreme Court delay complicates CFPB's aggressive agenda push," S&P Global Market Intelligence, March 2, 2023 (Eamonn Moran quoted)
• "CFPB cracks down on subscription fees," S&P Global Market Intelligence, January 20, 2023 (Eamonn Moran quoted regarding "negative option" subscription programs)
• "CFPB moves full steam ahead with bank oversight despite intensifying headwinds," S&P Global Market Intelligence, December 29, 2022 (Eamonn Moran quoted)
• "CFPB guidance, enforcement hang in the balance of US Supreme Court appeal," S&P Global Market Intelligence, November 30, 2022 (Eamonn Moran quoted)
• "CFPB targeting largest US banks as it cracks down on financial industry," S&P Global Market Intelligence, November 16, 2022 (Eamonn Moran quoted)
• "CFPB to Meet with Trade Groups Over Peer-to-Peer Payment Fraud," Bloomberg Law, September 12, 2022 (Eamonn Moran quoted)
• "Chopra's expansive vision for CFPB authority is facing industry pushback," American Banker, May 11, 2022 (Eamonn Moran quoted)
• "The State of BNPL + What's To Come [Roundtable Recap], PerformLine, March 30, 2022
• "CFPB's deadline looms for BNPL players," Payments Dive, February 17, 2022 (Eamonn Moran quoted)
• "CFPB Opens Up Rule Petitions in Bid to Reduce Industry Influence," Bloomberg Law, February 16, 2022 (Eamonn Moran quoted)
• "CFPB Revamps Its Rule Suggestion Box To Boost Public Input," Law360, February 16, 2022 (Eamonn Moran quoted)
• "CFPB Flips on Trump-era Abusive Acts Stance," Compliance Week, March 15, 2021 (Eamonn Moran quoted)
• "How Far Left Will CFPB Swing in 2021?", American Banker, December 29, 2020 (Eamonn Moran quoted)
• "Debt Collectors Will Soon Be Allowed to Reach You by Text," CBS Moneywatch, November 5, 2020 (Eamonn Moran quoted)
• "Emails, Texts from Debt Collectors? More Repayment Reminders Could Be Coming Under a New Rule," USA Today, November 4, 2020 (Eamonn Moran quoted)
• "CFPB Debt Collection Rule Sets Up Long Fight for Attorneys," Bloomberg Law, November 3, 2020 (Eamonn Moran quoted)
• "CFPB Readies Debt Collection Rules for Long Overdue Tech Update, Bloomberg Law, October 13, 2020 (Eamonn Moran quoted)
• "CFPB May Trip Over Dodd-Frank in Mortgage Rule Revamp," Bloomberg Law, October 6, 2020 (Eamonn Moran quoted)
• "CFPB's Latest Underwriting Revamp Seen as Boon to Fintechs, GSEs," American Banker, September 2, 2020 (Eamonn Moran quoted)
• "OCC True Lender Clarification to Establish Legal Certainty for Online Lenders," Global Capital, July 24, 2020 (Eamonn Moran quoted)
• "CFPB Finalizes Rule Allowing Banks to Estimate Remittance Costs," Bloomberg Law, May 11, 2020 (Eamonn Moran quoted)
• "CFPB Finalizes Wider Safe Harbor For Remittance Rule," Law360, May 11, 2020 (Eamonn Moran quoted)
• "New Standardized Practices for Fintech," Atlanta Business Chronicle, March 8, 2018 (Eamonn Moran quoted)
• Publications
  • Co-Author, "Office of the Comptroller of the Currency Issues 'Buy Now, Pay Later' Guidance to Banks," The Banking Law Journal, Vol. 141, No. 4 (April 2024)
  • Co-Author, "Inside Bank Regulators' Community Lending Law Overhaul," Law360, November 15, 2023
  • Author, "Takeaways From Recent Developments In Bank-Fintech Space," Law360, September 19, 2023
  • Author, "Financial Services, Fintech Are Top CFPB Areas To Watch," Law360, February 7, 2023
  • Co-author, "Buy now, pay later: Developments in the UK, United States and Australia," Thomson Reuters Regulatory Intelligence, January 30, 2023
  • Author, "How FTC Proposal Would Tighten Rules on Auto Finance," Law360, July 7, 2022
  • Co-author, "Proposed Trade Regulation Rule on Auto Dealer Sales Practices Could Dramatically Affect Auto Finance," Morgan Lewis, June 24, 2022
  • Co-author, "Bipartisan Proposal Attempts to Provide Solutions for Comprehensive Regulation of Digital Assets," Morgan Lewis, June 15, 2022
  • Co-author, "CFPB Spring Supervisory Highlights Detail Agency Findings and Priorities," Morgan Lewis, May 4, 2022
  • Co-author, "M&A in the Ever-Changing Fintech Landscape," Morgan Lewis, March 8, 2022
  • Co-author, "Buy Now, Pay Later: Balancing Credit Access with Consumer Protection," Morgan Lewis, February 16, 2022
  • Co-author, "'Madden Fix' Rules Withstand a Key Test: What Happens Next," Morgan Lewis, February 10, 2022
  • Co-author, "CFPB's Probe of Buy Now, Pay Later: What's the Risk to Consumers?," Bloomberg Law, February 7, 2022
  • Co-author, "CFPB Pans Credit Reporting Agency Consumer Complaint Handling," Morgan Lewis, January 10, 2022
  • Co-author, "Banking Agencies Release Proposed Guidance for Third-Party Relationships," Morgan Lewis, July 16, 2021
  • Co-author, "True Lender Rule Invalidated," Morgan Lewis, July 1, 2021
  • Co-author, "CFPB Finalizes Delay of Mandatory Compliance Date for General Qualified Mortgage Final Rule," Morgan Lewis, April 28, 2021
  • Co-author, "Members of Congress Introduce Joint CRA Resolution to Overturn the OCC's True Lender Rule," Morgan Lewis, March 30, 2021
  • Co-author, "Federal Banking Regulators Support Treasury's Investments in Minority Depository Institutions and Community Development Financial Institutions," Morgan Lewis, March 16, 2021
  • Co-author, "Elections Have Consequences: Biden's CFPB Leadership Rescinds Previous Administration Self-Fencing of Enforcement Authority," Morgan Lewis, March 15, 2021
  • Co-author, "CFPB Proposes Delay of Mandatory Compliance Date for General Qualified Mortgage Rule," Morgan Lewis, March 4, 2021
  • Co-author, "CFPB Provides Status Update Concerning Recently Finalized Qualified Mortgage Rules," Morgan Lewis, February 24, 2021
  • Co-author, "New Administration, More Forbearance: Biden Administration Announces Extension of COVID-19 Forbearance and Foreclosure Protections for Homeowners," Morgan Lewis, February 18, 2021
  • Co-author, "Acting CFPB Director Calls for Companies to Improve Responses to Consumer Complaints," Morgan Lewis, February 12, 2021
  • Co-author, "Key Financial Regulatory Issues for Biden Administration's Early Days," Morgan Lewis, February 11, 2021
  • Co-author, "CFPB's New Acting Director Signals Significant Shifts in Agency Direction, Policies, and Priorities," Morgan Lewis, February 8, 2021
  • Co-author, "California DFPI Staffs Up, Begins Investigating Previously Out-of-Reach Businesses," Morgan Lewis, January 19, 2021
  • Co-author, "Fair Lending Focus: CFPB Issues Statement on Serving Consumers with Limited English Proficiency," Morgan Lewis, January 15, 2021
  • Co-author, "CFPB Finalizes Qualified Mortgage Changes," Morgan Lewis, December 11, 2020
  • Co-author, "Consumer Financial Protection Outlook," Morgan Lewis, November 19, 2020
  • Co-author, "CFPB Issues Final (and First Ever) Debt Collection Rule," Morgan Lewis, November 9, 2020
  • Co-author, "OCC's Final 'True Lender' Rule Should Boost Bank Lending, Law360, October 30, 2020
  • Co-author, "OCC Issues Final True Lender' Rule," Morgan Lewis, October 28, 2020
  • Co-author, "Banking Agencies Release Proposed Rule on the Nonbinding Role of Guidance," Morgan Lewis, October 23, 2020
  • Co-author, "CFPB Issues Final Rule Extending the Qualified Mortgage GSE Patch'," Morgan Lewis, October 21, 2020
  • Co-author, "CFPB Issues Guidance Regarding Applications for Early Termination of Consent Orders," Morgan Lewis, October 6, 2020
  • Co-author, "Let's Be Civil': White House Due Process Memo May Improve Enforcement in Financial Regulatory Matters," Morgan Lewis, October 1, 2020
  • Author, "Bank Lessons From OCC's Stablecoin Custody Go-Ahead, Law360, September 25, 2020
  • Co-author, "OCC Issues Clarification on Stablecoin Custody Services," Morgan Lewis, September 23, 2022
  • Co-author, "CFPB Outlines Small Business Lending Data Collection Rule Proposals," Morgan Lewis, September 16, 2020
  • Co-author, "California Means Business (Regulation) with New Mini-CFPB' Law," Morgan Lewis, September 14, 2020
  • Co-author, "COVID-19 Update: CDC Announces a Nationwide Ban on Residential Evictions," Morgan Lewis, September 3, 2020
  • Co-author, "Second Update: FHFA Announces Latest Extension of Moratorium on Foreclosures and Evictions," Morgan Lewis, August 31, 2020
  • Co-author, "Update: US Secretary of Education Implements Presidential Memorandum for Student Loan Payment Relief," Morgan Lewis, August 25, 2020
  • Co-author, "CFPB Proposes New Seasoned' Qualified Mortgage Category," Morgan Lewis, August 20, 2020
  • Co-author, "Executive Actions Provide Limited Mortgage, Rental, and Student Loan Relief," Morgan Lewis, August 10, 2020
  • Co-author, "Financial Institutions Encouraged to Consider Additional Options for Consumer and Commercial Borrower Accommodations," Morgan Lewis, August 7, 2020
  • Co-author, "OCC Issues Proposed True Lender' Rule," Morgan Lewis, July 23, 2020
  • Co-author, "OCC Plans to Introduce Special Purpose National Bank Charter for Payments Companies," Morgan Lewis, July 13, 2020
  • Co-author, "FDIC Issues Madden Rule and Affirms Valid When Made' and Most Favored Lender' Doctrines," Morgan Lewis, July 2, 2020
  • Co-author, "Supreme Court: CFPB's Structure Is Unconstitutional, Director Must Serve at President's Pleasure," Morgan Lewis, June 29, 2020
  • Co-author, "CFPB Issues Interim Final Rule Regarding Loss Mitigation Options for Homeowners Impacted by COVID-19," Morgan Lewis, June 26, 2020
  • Co-author, "CFPB Proposes Substantial Amendments to Qualified Mortgage Definition, Addresses GSE Patch," Morgan Lewis, June 26, 2020
  • Co-author, "CFPB Launches Pilot Advisory Opinion Program, Solicits Comment," Morgan Lewis, June 22, 2020
  • Co-author, "OCC Madden Rule is First Step Toward Needed Clarity for Banks, Fintechs, and Nonbank Lenders, Westlaw," Morgan Lewis, June 22, 2020
  • Co-author, "Update: FHFA Announces Further Extension on Moratorium on Foreclosures and Evictions," Morgan Lewis, June 18, 2020
  • Co-author, "OCC Madden Rule Is First Step Toward Needed Clarity for Banks, Fintechs, and Nonbank Lenders," Morgan Lewis, June 5, 2020
  • Co-author, "FHFA Announces Extension on Moratorium on Foreclosures and Evictions; Provides New COVID-19 Forbearance Payment Deferral Repayment Option," Morgan Lewis, May 18, 2020
  • Co-author, "COVID-19: What Servicers Should Know About Managing Mortgage Loan Forbearances," Morgan Lewis, May 12, 2020
  • Co-author, "FHFA Announces Four-Month Limit to Servicer Advances for CARES Act Forbearance; Fannie Mae and Freddie Mac Will Purchase Qualified Loans in Forbearance," Morgan Lewis, April 24, 2020
  • Co-author, "FTC Settlement May Raise the Compliance Bar for Fintechs," Morgan Lewis, April 23, 2020
  •  Author, "Key Takeaways: Federal, State Emergency Actions Affecting Residential and Commercial Real Estate," Morgan Lewis, April 16, 2020
  • Co-author, "California Executive Orders Provide Consumer and Commercial Relief During COVID-19," Morgan Lewis, March 31, 2020
  • Co-author, "New Jersey Governor Announces Mortgage Payment Relief, Financial Protections for Residents," Morgan Lewis, March 31, 2020
  • Co-author, "Foreclosures and Evictions Temporarily Suspended for Fannie and Freddie Mortgages," Morgan Lewis, March 19, 2020
  • Co-author, "CFPB Announces New Steps to Prevent Consumer Harm," Morgan Lewis, March 12, 2020
  • Co-author, "Will Regulatory Rollback in the Nation's Capital Work?" Morgan Lewis, March 6, 2020
  • Co-author, "Watch Out for California – State Stepping Up Fintech and Lending Regulatory Enforcement," Morgan Lewis, March 5, 2020
  • Co-author, "Making It the Same Everywhere: States Strive for Uniformity in Money Transmitter Laws, Thomson Reuters," Morgan Lewis, February 3, 2020
  • Co-author, "CFPB Issues Long-Anticipated Framework for Abusive' Acts and Practices Supervision and Enforcement," Morgan Lewis, January 27, 2020
  • Co-author, "As California Financial Regulation Goes, So Goes the Nation': California Governor Proposes New and Expansive Consumer Protection Law," Morgan Lewis, January 14, 2020
  • Co-author, "California Financing Law: New Requirements on Consumer Loans," Morgan Lewis, November 21, 2019
  • Co-author, "Making It the Same Everywhere: States Strive for Uniformity in Money Transmitter Laws," Morgan Lewis, November 8, 2019
  • Co-author, "Payment Apps – Watch Out for State Attorney General Enforcement," Morgan Lewis, November 7, 2019
  • Co-author, "CFPB, State Regulator Partner in Loan Broker Suit," Morgan Lewis, October 4, 2019
  • Author, "CFPB Revises Trial Disclosure Policy and Issues Compliance Assistance Sandbox Policy," Morgan Lewis, October 2, 2019
  • Co-author, "CFPB Issues First No-Action Letter Under Newly Revised Policy," Morgan Lewis, September 19, 2019
  • Author, "CFPB and State Regulators Launch American Consumer Financial Innovation Network," Morgan Lewis, September 11, 2019
  • Author, "AI's Role In Financial Services: Some Early Lessons," Law360, November 14, 2018
  • Author, "The Growing Power of Fintech Lenders, BankDirector," Morgan Lewis, October 13, 2017
  • Author, "Electronic Mortgage Closings Improve Homebuying: Part 2," Law360, August 11, 2017
  • Author, "Electronic Mortgage Closings Improve Homebuying: Part 1, Law360, August 10, 2017
  • Author, "The CFPB's Enforcement Of The Prohibition On Abusive Acts And Practices, Bloomberg BNA Banking Report
  • Author, "Understanding and Applying Dodd-Frank's Abusive' Standard," Bloomberg BNA Banking Report, February 10, 2015
  • Author, "The Uncertain Utility Of A CFPB No-Action Letter, Law360," October 2014

• Speaker, "Third Circuit Says Student Loan Trusts Are 'Covered Persons' Subject to the CFPA," Securitization Insight Podcast, Episode 57, March 25, 2024

• Speaker, "Oral Arguments in Two Cases Challenging Chevron Deference and Potential Impact on US Regulatory Agencies," Securitization Insight Podcast, Episode 55, February 5, 2024

• Speaker, "What's in Your Wallet: the CFPB Goes after Digital Wallets and Payment Apps," New York City Bar Task Force on Digital Technologies Podcast (December 21, 2023).  

• Speaker, "Oral Arguments in the CFPB Funding Case," Securitization Insight Podcast, Episode 51, November 13, 2023
• Speaker, "Impact of Recent Regulatory Enforcement Actions on Bank-FinTech Partnerships," Securitization Insight Podcast, Episode 42, May 15, 2023
• Eamonn Moran presented at the New York City Bar Association's Structured Finance & Securitization Committee's meeting on January 31, 2023.  He updated the committee on the top regulatory priorities and trends in the consumer financial services and fintech sectors, and offered some thoughts and perspective as to what to expect in 2023.

• Speaker, "CFPB BNPL report insights," Fintech Pulse Podcast, Episode 10, October 28, 2022

• Speaker, "CFPB, Consumer Protection and Securitization: Current Topics," Securitization Insight Podcast, Episode 29, October 24, 2022
• Speaker, PerformLine Buy Now, Pay Later Roundtable (March 2022)
• Eamonn Moran presented at the New York City Bar Association's Structured Finance & Securitization Committee's meeting on January 27th, 2022. He updated the committee on recent developments in state legislation and regulation of consumer lending practices (i.e., potential required licensing of passive owner entities) and the new Consumer Financial Protection Bureau related decision in the National Collegiate Trust litigation and its potential impact on structured finance/securitization special purpose entities (SPEs).
• BWG Strategy's BNPL CFPB Regulatory Outlook (January 2022)
• National Council of Higher Education Resources 2016 Winter Legal Meeting (January 2016)

• Consumer Financial Services Committee, American Bar Association, Member
• Banking Law Committee, American Bar Association, Member
• Georgetown University Alumni Association, Board of Governors, 2014–present
• Georgetown Alumni Club of Metropolitan Washington, DC, President, 2015–2019
• Georgetown Alumni Club of Metropolitan Washington, DC, Secretary, 2011–2015
• Hoyas Unlimited, Board of Directors, 2015–2021
• Hoya Hoop Club, Board of Directors, 2013–2022