As a former senior in-house lawyer at multiple national financial institutions, Randy brings extensive experience to the Litigation and Financial Regulatory Advice & Response groups.

Overview

As Deputy General Counsel for the consumer bank at PNC Financial, Randy managed the legal team that supported all of PNC's consumer banking and loan products, channels, and regulatory matters. He provided direct support to the bank’s fair lending operations and was the principal counsel to PNC’s Chief Customer Officer. In addition, he coordinated consumer bank legal activity for examinations by various regulators, including the Office of the Comptroller of Currency and the Consumer Financial Protection Bureau. He previously served as General Counsel for Fleet Mortgage, and as an Associate General Counsel at Bank of America, where he managed legal teams that supported various loan products and related servicing operations.

Randy began his legal career at the U.S. Department of Commerce in Washington, D.C., and later was in private practice where he handled a wide variety of mortgage finance litigation and regulatory matters. Randy is admitted to practice law in the District of Columbia; at MVA, he will provide advice to institutional clients regarding federal regulatory matters.

Representative Experience

  • Successfully defended a large national builder before a state real estate commission involving alleged violations by sales agents of the federal Real Estate Settlement Procedures Act (RESPA)
    • Provided RESPA guidance for bank joint marketing and affiliated business arrangement programs
  • Represented a large national bank in providing advice under Regulation B, Regulation DD, Regulation E, and UDAAP on a wide range of deposit product and lending matters, including requirements for  joint applicants and guarantors
  • Guided several national banks in the establishment of their fair lending monitoring and compliance programs, including the testing, reporting, training and regulatory management components of those programs
    • Represented national banks in fair lending regulatory investigations and enforcement actions relating to mortgage and indirect auto originations
    • Provided ongoing fair lending guidance to several national financial institutions and lenders, including guidance on Limited English Proficiency policies and practices
  • Advised a regional bank on the changes arising under the Regulation Z LIBOR transition rule of the Bureau of Consumer Financial Protection (CFPB)
  • Represented a large national bank with respect to demands under the Federal Trade Commission (FTC) Holder Rule on auto finance installment sales contracts
  • Oversaw the review of and revisions to a national bank’s product sales practices, as well as the subsequent horizontal regulatory examination of those practices
  • Advised a national bank on the establishment of its business and compliance response program with the CFPB, and the development of its UDAAP product review program
    • Provided guidance on the establishment of the program for legal review and resolution of customer complaints
  • Provided guidance under the Credit Repair Organizations Act (CROA) and the FTC’s Telemarketing Sales Rule for the prospective acquisition of a credit repair business
  • Provided legal advice to a national lender on the requirements of the Secure and Fair Enforcement for Mortgage Licensing Act (SAFE Act)
  • Provided guidance to a large national bank on commercially reasonable security procedures required for wire systems under UCC 4A and the Federal Financial Institutions Examination Council (FFIEC)
  • Provided regulatory guidance under Regulation Z on the operational requirements for suspensions, terminations and reinstatements of home equity lines of credit (HELOCS) during periods of economic decline
    • Identified and successfully resolved litigation filed to recover on HELOC lien protection insurance policies for national banks
  • Guided a lender of distressed loan servicing portfolios with loss mitigation and exit strategies
    • Provided legal guidance on the sale of non-performing and charged off loans, and the regulatory best practices related to those transactions
  • Provided guidance to a national bank on the implementation of arbitration provisions in agreements for various bank products
  • Advised various business units of a national bank on compliance and mitigation efforts relating to compliance with the Telephone Consumer Protection Act (TCPA)
  • Successfully implemented a mitigation program and resolution of vehicle repossession issues by a national servicer
  • Provided legal guidance to a national bank for the economically sound refinance of student loans
  • Provided guidance to a national bank on the development and operation of an elder and vulnerable adult exploitation program

News

Education

J.D., University of Akron School of Law, 1983, cum laude, Law Review Case and Comment Editor

B.F.A., Bowling Green State University, 1978, cum laude

Admissions

  • United States Supreme Court 1990
  • District of Columbia, 1989
  • United States Court of Appeals for the District of Columbia Circuit 1988
  • United States Court of Appeals for the Fourth Circuit 1986
  • *Licensed in District of Columbia. Not licensed in North Carolina. Practicing in North Carolina pursuant to NC Rule of Professional Conduct 5.5(d)(2). 
Jump to Page

By using this site, you agree to our updated Privacy Policy and our Terms of Use.