founding attorney and managing member
Troy is a business owner’s lawyer, priding himself on a results-oriented, pragmatic approach to addressing legal issues in the financial services world. In his words, “I find out what the business wants, what it needs. If I start there, I can often find a way to get them to the result wanted, or very close to it, in a legal and compliant way.”
Troy deals with federal and state compliance, enforcement defense, company formation, and mergers and acquisitions (M&A). In these areas, Troy represents independent mortgage bankers (IMBs), community banks and other depositories, homebuilders, and related entities (e.g., lenders, servicers, title companies, secondary market investors, and equity funds).
Troy is active in the industry, including being significantly involved with industry associations and currently is a board member, and Chair of the Regulatory Compliance Committee of the Texas Mortgage Bankers Association. In 2007, the Mortgage Bankers Association named him to the Future Leader’s program.
Troy is a frequent speaker on a wide range of mortgage banking related issues, and in recent years has spent much of his time focused on the CFPB.
Conducted due diligence review of mortgage originators and servicers in multi-billion dollar transactions.
Assisted investment bankers and hedge funds in acquisitions of lenders and servicers.
Represented lenders and related companies in proceedings before the CFPB, HUD, and other regulators.
Negotiated and drafted agreements for affiliated business, marketing, private label, and correspondent lending arrangements.
Negotiated and drafted employment agreements for lenders and affiliated companies.
Representing companies in proceedings before regulatory agencies, including the Consumer Financial Protection Bureau (CFPB), Department of Housing and Urban Development (HUD), Federal Housing Administration (FHA), federal and state banking examiners, and insurance commissions.
Advising clients on a broad suite of origination and servicing issues.
Advising on federal and state law compliance issues, including under RESPA, TILA, FCRA, Fair Lending, privacy, and similar laws.
Creating and implementing compliance management systems, policies, and procedures.
Counseling on the requirements of FHA, VA, Fannie Mae, Freddie Mac, and private investors, guarnators, and insurers.
Assisting companies with repurchase and indemnification demands.
Conducting in-depth due diligence reviews on companies in anticipation of major transactions.
Forming joint ventures and assessing marketing services agreements and other strategies under RESPA.
- Washington College of Law (1997), magna cum laude
founding Attorney and managing member
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 a founding member of Garris Horn PLLC. Richard was most recently in private practice at Richard Horn Legal PLLC.
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. He advises on all regulations issued by the CFPB and other consumer finance laws, including TRID, RESPA, TILA, FCRA, UDAAP, state high cost lending laws, and state licensing laws. He also advises clients on regulatory examination preparation, investigations, and enforcement actions. Richard also assists clients with submitting comment letters to federal and state rulemakings.
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.
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
Consumer Financial Protection Bureau (CFPB), Senior Counsel & Special Advisor
Federal Deposit Insurance Corporation (FDIC), Senior Attorney
New York University School of Law (J.D., 2003)
Brown University (A.B., 2000)