Richard Horn

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 currently 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.

In private practice and in government, Richard has worked on consumer compliance and risk management supervisory matters and enforcement actions. He has worked on many regulatory issues, including:

• TRID

• TILA, including the Ability-to-Repay/Qualified Mortgage, Loan Originator Compensation, Higher-Priced Mortgage, and HOEPA rules.

• RESPA (including marketing services agreements, joint ventures/affiliated businesses, and other arrangements that implicate RESPA Section 8)

• Fair lending enforcement and internal reviews under Equal Credit Opportunity Act and Fair Housing Act

• Unfair, Deceptive, or Abusive Acts or Practices (UDAAP)

• Privacy and credit reporting, including FCRA and GLBA

• State licensing, disclosure, and fee restrictions and requirements

• Comment letters on rulemakings

• Community Reinvestment Act.

Richard also represented Townstone Financial, Inc. throughout the CFPB’s fair lending investigation, and the company’s win against the CFPB’s fair lending lawsuit.  Richard represents all types of companies and individuals facing CFPB supervision and enforcement matters, as well as state regulatory agency matters.

Richard understands the rulemaking process and the policy issues facing the CFPB, having led a major rulemaking at the CFPB.  He has worked on numerous comment letters on rulemakings, bringing this experience to bear. 

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

EDUCATION

• New York University School of Law (J.D., 2003)

• Brown University (A.B., 2000)

BAR ADMISSIONS

• Arizona

• New York

• District of Columbia

ASSOCIATIONS

• Board Member of CFPB Alumni Association

PUBLICATIONS

• CONFERENCE ON CONSUMER FINANCE LAW QUARTERLY REPORT VOL. 72 NO.3, "THE CFPB’S TRIAL DISCLOSURE PROGRAM AUTHORITY COULD SOON BECOME MORE INTERESTING TO THE INDUSTRY" - Richard Horn authored an article in the Spring 2019 issue of the Consumer Finance Law Quarterly Report, titled "The CFPB’s Trial Disclosure Program Authority Could Soon Become More Interesting to the Industry." The article provides editorial on the CFPB’s trial disclosure for subjects of interest for the industry. View

• JOURNAL OF PUBLIC POLICY & MARKETING, "THE CONSUMER FINANCIAL PROTECTION BUREAU'S CONSUMER RESEARCH: MISSION ACCOMPLISHED?" - Richard Horn authored an article in the Spring 2017 issue of the Journal of Public Policy & Marketing, titled "The Consumer Financial Protection Bureau's Consumer Research: Mission Accomplished?" The article critiques the CFPB’s consumer research for some of its most important rules and consumer initiatives. View

• MORTGAGE BANKERS ASSOCIATION’S COMPLIANCE ESSENTIALS GUIDE FOR THE TILA-RESPA INTEGRATED DISCLOSURES - Richard Horn co-authored the Mortgage Bankers Association’s Compliance Essentials Guide for the TILA-RESPA Integrated Disclosures. Purchase your copy of this excellent guide today! View

• MORTGAGE COMPLIANCE MAGAZINE, "THE TILA-RESPA INTEGRATED DISCLOSURES: THE BEGINNER'S GUIDE TO IMPLEMENTATION" - Richard Horn authored an article for Mortgage Compliance Magazine’s January 2015 issue, titled The TILA-RESPA Integrated Disclosures: The Beginner's Guide to Implementation.