Joseph J. Reilly Senior Counsel

Joe Reilly has nearly two decades of experience representing financial institutions in a wide variety of regulatory, enforcement and litigation matters. He advises lenders, Fintech start-ups and other financial services providers on a broad range of compliance and lending authority matters, and has defended those clients in enforcement actions, informal investigations and in examinations by the CFPB, OCC, Federal Reserve, FDIC, SEC, numerous state agencies, and the mortgage GSEs.

Joe’s compliance counseling covers the entire panoply of consumer and business lending laws and rules under TILA/Reg. Z, ECOA/Reg. B, RESPA/Reg. X, UDAAP, EFTA/Reg. E, Fair Credit Reporting Act, debt-collection laws, GLBA privacy provisions, state licensing regimes and others. For bank and bank-affiliated clients, Joe also advises on bank powers, federal preemption, interstate expansion, and a range of Bank Holding Company Act matters, including rules on inter-affiliate transactions, tying, and director qualifications. 

Joe also advises federally chartered Farm Credit lenders on similar issues of authority, preemption and compliance across the range of their lending and investment activities.

Joe actively works with the American Bankers’ Association, and is the principal author of the ABA’s most popular publication ever: “The CFPB Mortgage Origination Rules Deskbook,” (equally applicable to non-bank lenders). The 624- page treatise, now in its 2nd edition, is the authoritative volume on mortgage lending regulations mandated by the Dodd-Frank Act, including those on QMs and Loan Originator Compensation. Joe also advises on many other mortgage-law issues, including RESPA’s anti-kickback provisions, fair lending and servicing, state licensing, mortgage-insurance considerations, disclosures, and contract terms.

Joe has been quoted in the Wall Street Journal and numerous other publications on recent developments involving the CFPB and other regulatory agencies. He has also been an active member of the Banking Law and Consumer Financial Committees of the American Bar Association, having served as Vice Chair of the latter’s Truth-in-Lending Subcommittee.

Joe began his financial services work before law school, serving 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.  Later, during a break from his law practice, Joe was an Investment Banking Associate at Credit Suisse, holding the Series 7 (General Securities Representative) license. 

Education.  An Order of the Coif graduate of the University of Virginia School of Law, Joe was an Editor of the Virginia Law Review.  He earned his bachelor’s degree from Stanford University in Quantitative Economics and Public Policy, while on a U.S. Army ROTC scholarship.

Clerkships.  Joe clerked on the U.S. Court of Appeals for the Second Circuit for Judge Dennis Jacobs; and in the EDNY for Judge Reena Raggi.

Admissions.  Joe is admitted to practice in New York and Washington, DC.

Experience

Representation of a major non-bank mortgage servicer in responding to a CFPB investigation and Notice and Opportunity to Respond and Advise to serious allegations regarding data integrity, purported UDAAPs, and illegal debt collection actions.

Fair lending advice under ECOA and the Fair Housing Act to a wide range of bank and non-bank institutions.

Representation of two top 10 banks and numerous other institutions in preparing for and responding to CFPB examinations, including preparation of written responses to CFPB questions.

Advice to numerous banks and non-banks on the CFPB’s loan-originator compensation, QM and other key mortgage rules.

Advice to a top 5 bank and many other servicers on preparing to implement the CFPB’s mortgage servicing rules.

Representation of a top 10 bank and numerous other clients in acquisition due diligence of consumer-finance businesses.

Advice to top 5 national banks on federal preemption of state consumer-finance laws.

RESPA compliance advice to numerous settlement services providers.

Representation of two large national banks in connection with Office of the Comptroller of the Currency and state attorney general investigations into alleged “robo-signing” and other defects in the foreclosure process.

  • University of Virginia School of Law, JD, Order of the Coif, Editor, Virginia Law Review, 1999
  • Stanford University, AB, Quantitative Economics & Public Policy (Army ROTC Scholarship), 1991
Co-Vice Chair, Truth-in-Lending Subcommittee, Am. Bar Ass’n Consumer Financial Services Committee, 2015-present
  • District of Columbia
  • New York
  • U.S. Court of Appeals for the 2nd Circuit
  • U.S. Court of Appeals for the District of Columbia Circuit
  • U.S. District Court for the District of Columbia
  • U.S. District Court for the Eastern District of New York
  • U.S. District Court for the Southern District of New York
  • U.S. Supreme Court
  • Moderator, "Key Considerations," The CFPB’s Proposed Debt-Collection Rule, McGuireWoods Webinar, June 12 & 20, 2019
  • Speaker, "TRID - The View from Non-Lenders," American Bar Association Consumer Financial Services Law Committee Meeting, January 11, 2016
  • Speaker, "Is Your Bank Prepared to Implement the TILA/RESPA Integration Rule?," American Bankers Association’s Real Estate Lending Conference, April 9, 2015
  • Speaker, "New CFPB Mortgage Origination Rules," American Bankers Association Briefing Webinar Series, Parts 1-5, February 26–June 25, 2015
  • Speaker, "CFPB Rulemaking Update," Firm Webinar, February 3, 2015
  • Speaker, "Discussing ‘The New CFPB Mortgage Origination Rules Deskbook'," Firm Webinar, October 28, 2014
  • Speaker, "Where Are We Now? Mortgage Disclosures and Other Regulatory Compliance Hot Topics," South Florida Compliance Association Seminar, October 7, 2014
  • Speaker, "Mortgage Origination & Servicing in Focus," Firm CFPB Today Conference, October 6, 2014
  • Speaker, "Mortgage Origination Challenges for Industry," American Bar Association’s Business Law Section Annual Meeting, September 11, 2014
  • Moderator, "The New TRID Rule," American Bar Association’s Consumer Financial Services Committee Meeting, January 11, 2014
  • Speaker, "Last-Minute QM Doublecheck," Inside Mortgage Finance Webinar, December 12, 2013
  • Speaker, "The CFPB’s Mortgage Rules, HUD’s Disparate Impact Rule, and More," American Bar Association Annual Meeting, August 10, 2013
  • Speaker, "The Pros and Cons of Your ‘Plan B’ Options," RESPRO Webinar, July 10, 2013
  • Speaker, "The New Loan Servicing Standards," October Research Webinar, March 21, 2013
  • Speaker, "New Mortgage Environment: CFPB’s New Rules," Firm Webinar, February 13, 2013
  • Speaker, "The Ability-to-Repay/Qualified Mortgage Rule: The Saga Continues," American Bar Association Consumer Financial Services Committee Winter Meeting, January 6, 2013
  • Speaker, "Re-Regulating the Mortgage Market: Making Sense of Over 2,000 Pages of CFPB Rule Proposals," Risk Management Association’s Annual Risk Management Conference, October 29, 2012
  • Speaker, "Mortgage Servicing Update: Understanding and Complying with the New and Evolving Rules and Regulations in Light of Recent OCC and CFPB Activity," Firm Webinar, November 9, 2011
  • Speaker, "The Regulatory Response to the Foreclosure Crisis: What Bank Servicers Need to Do to Meet the OCC’s September 30 Deadline," Firm Webinar, July 13, 2011
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