Richard Horn is a former Senior Counsel & Special Advisor in the Consumer Financial Protection Bureau’s Office of Regulations and a former Senior Attorney at the FDIC. Richard is current Co-Managing Partner of Garris Horn LLP.
At the CFPB, Richard led the final rulemaking for the integrated disclosures under the Truth in Lending Act and the Real Estate Settlement Procedures Act (the TILA-RESPA Integrated Disclosure rule, also known as “TRID”). He also led the CFPB’s design of the integrated disclosures, as well as the qualitative and quantitative consumer testing of the disclosures. As a key architect of the TRID rulemaking, Richard is one of the foremost experts on the rule.
Prior to joining the CFPB, Richard was a senior attorney at the Federal Deposit Insurance Corporation (FDIC) in the New York Regional Office. At the FDIC, Richard worked on consumer compliance and risk management supervisory matters and enforcement actions. He worked on many regulatory issues including: TILA; RESPA (including marketing services agreements and joint ventures/affiliated business arrangements); UDAP; FCRA; GLBA; bank merger act applications; capital requirements and prompt corrective action; Community Reinvestment Act; and fair lending under ECOA and the Fair Housing Act.
Having led a major rulemaking at the CFPB, Richard understands the rulemaking process, the policy issues facing the CFPB, and can represent institutions dealing with the CFPB supervisory and enforcement process. Richard also has experience representing clients with state regulatory agencies in supervisory matters. Richard advises clients of all sizes, including banks, credit unions, non-bank mortgage lenders and brokers, title underwriters and agents, investors, and technology vendors on all state and federal regulatory compliance matters for consumer lending.
Representative Matters
• Represented non-depository mortgage lenders in CFPB fair lending and other investigations
• Advised depository and non-depository lenders, title companies, and technology companies regarding compliance with TRID, ATR/QM, RESPA section 8, and HMDA
• Drafted marketing services agreements and joint venture operating agreements addressing corporate and RESPA section 8 issues
• Reviewed loan documents and disclosures for construction-to-permanent lending program
• Assisted company with consumer testing of financial documents
• Advised fintech company regarding privacy and data security requirements
Experience
• Consumer Financial Protection Bureau (CFPB), Senior Counsel & Special Advisor
• Federal Deposit Insurance Corporation (FDIC), Senior Attorney
