Anoush Garakani

Anoush Garakani is co-leader of Alston & Bird’s Consumer Financial Services Team. His practice focuses on mortgage banking and consumer finance, with an emphasis on counseling clients on compliance with federal and state consumer financial protection laws and regulations. He also guides clients through investigations and enforcement actions involving consumer financial services. His experience includes a clerkship with the Federal Trade Commission’s Division of Financial Practices.

Anoush advises on the CFPB’s Mortgage Servicing Rules and a range of federal statutes, including the Fair Credit Reporting Act, Equal Credit Opportunity Act, Fair Debt Collection Practices Act, Truth in Lending Act, and Servicemembers Civil Relief Act. His work also addresses federal and state prohibitions on unfair or deceptive acts or practices. Across these frameworks, he counsels on requirements affecting mortgage origination and servicing, debt collection, retail installment sales contracts, telemarketing, and the use of autodialer systems.

In transactional contexts, Anoush assists with regulatory compliance due diligence for investments and acquisitions involving consumer financial products, including mortgage loans and secured and unsecured consumer loans. Best Lawyers: Ones to Watch has recognized him since 2021 for his work in Corporate Governance and Compliance Law.

• Counseling clients on compliance with state and federal laws affecting lending and servicing activities, including the Real Estate Settlement Procedures Act (RESPA), Truth in Lending Act (TILA), Equal Credit Opportunity Act (ECOA), Fair Credit Reporting Act (FCRA), Servicemembers Civil Relief Act (SCRA), and Fair Debt Collection Practices Act (FDCPA).
• Counseling clients on compliance with the Coronavirus Aid, Relief, and Economic Stability (CARES) Act’s mortgage relief and credit reporting provisions, including CARES Act guidance issued by Fannie Mae, Freddie Mac, HUD/FHA, VA, and USDA.
• Assisted in responding to requests from the House Financial Services Committee, Consumer Financial Protection Bureau (CFPB), and VA for documents and information related to CARES Act compliance.
• Conducted a review of state licensing and regulatory requirements applicable to providers of early wage access services.
• Assisted a provider of early wage access services in responding to a multistate inquiry, led by the New York Department of Financial Services, into the early wage access industry.
• Conducting enterprise-wide CFPB readiness reviews of a company’s business lines, operations, and products to assess the level of potential risks to consumers and evaluate a company’s compliance management program.
• Assisting companies in responding to CFPB-issued notices of potential action and request for response (PARR) letters.
• Defending administrative enforcement actions (including state government audits, single- or multistate examinations, and investigations) and assisting in litigation involving regulatory compliance issues.
• Defending administrative complaints filed pursuant to state civil rights statutes.
• Working with state regulators to obtain approvals, licenses, or regulatory guidance.

•  American University (J.D., 2013)
• University of California, Irvine (B.A., 2010)

•  California
• District of Columbia
• Maryland

• California Lawyers Association