Jim Milano advises clients on identifying, assessing, and addressing legal and regulatory risk in financial services projects. His work focuses on helping clients evaluate risk factors, analyze regulatory requirements, and develop structures and compliance approaches that account for those risks.
Jim also has over two decades assisting clients in administrative investigations and enforcement matters both at the federal and state level. Jim assists clients in responding to, defending, and resolving such matters. Jim handles investigations of consumer lending matters under the False Claims Act, Civil Investigative Demands from the Consumer Financial Protection Bureau, and subpoenas from states’ attorneys general, as well as the resolution of examinations by state consumer finance regulators.
Jim assists financial institutions—including mortgage companies, banking institutions, secondary market investors, consumer finance companies, and settlement service providers—with compliance under federal and state lending laws. He advises on digital marketing requirements under the Real Estate Settlement Procedures Act (RESPA) and counsels lenders and servicers on implementation of and compliance with the Federal Housing Administration’s Home Equity Conversion Mortgage (HECM) program. He also works with home equity access companies on home equity and appreciation-sharing products and sale-leaseback programs, including program design, regulatory approvals, and capital-raising activities.
His practice includes reviewing and structuring proprietary reverse mortgage loan programs and advising lenders, servicers, and settlement service providers—including appraisal management companies—on federal and state regulatory matters. Jim also represents clients in connection with regulatory inquiries and investigations and in resolving civil enforcement and disciplinary actions.
Earlier in his career, Jim assisted in the design and structuring of a patented Sharia-compliant declining balance co-ownership financing arrangement. His work consistently involves identifying and addressing regulatory and operational risks associated with mortgage and consumer finance programs while accounting for ongoing changes in federal and state law.
Representative Experience
Any result the lawyer or law firm may have achieved on behalf of clients in other matters does not necessarily indicate similar results can be obtained for other clients.
- Assisted mortgage lenders in responding to Consumer Financial Protection Bureau (CFPB) examinations and investigations.
- Reviewed proprietary reverse mortgage loan programs and documentation for multi-state offerings.
- Guided lenders and servicers in implementing and complying with the Federal Housing Administration (FHA) Home Equity Conversion Mortgage (HECM) program.
- Supported startup home equity access companies with program design, entity formation, regulatory approvals, and initial and subsequent capital raises.
- Advised lenders, servicers, and settlement service providers—including Appraisal Management Companies—on federal and state regulatory investigations, including defending and settling civil enforcement actions.
- Reviewed and provided commentary on federal and state legislation and regulatory pronouncements affecting client operations.
- Assisted private equity funds with investments in mortgage originators, servicers, and Appraisal Management Companies, including obtaining regulatory approvals for acquisitions.
- Advised clients on manufactured housing finance and manufactured home community regulatory matters.
Honors & Awards
- Recognized as a Fellow of the American Bar Foundation
- Elected as a Fellow of the American College of Consumer Financial Services Lawyers
- Received the Jim Mahoney Distinguished Service Award from Texas Reverse Mortgage Day, 2012
Professional & Civic Engagement
- American Bar Association, Business Law Section, Consumer Financial Services Committee, Programs Chair (Former Vice Chair)
- Conference on Consumer Finance Law (CCFL), Governing Committee (Former Chair)
- District of Columbia Bar Association
- Louisiana State Bar Association
- Maryland State Bar Association
- National Reverse Mortgage Lenders Association (NRMLA), Board of Directors
- State Bar of Georgia Association
- Virginia State Bar Association
Thought Leadership
Publications
- “Reverse Mortgages, Reframed: What the Industry Gets Wrong and What It Needs to Understand," Chrisman Commentary Daily Mortgage News, December 2025
- "Navigating Hazard Insurance Proceeds: Lender Rights in Reverse Mortgage Foreclosures," MortgagePOINT Magazine, March 2024
- "Construction-to-Permanent Financing Under Dodd-Frank’s ATR Rule and QM Safe Harbor," The Virginia Lawyer Magazine, December 2023
- "Years Later, D.C. District Court Reverses Course: HUD Rule Doesn’t Conflict with Fair Housing Act," American Bar Association, Business Law Today, October 2023
- "Agencies Propose Quality Control Standards for AVMs," American Bar Association, Business Law Today, August 2023
- "New Opportunities for Lenders and Borrowers under Special Purpose Programs," American Bar Association, Business Law Today, August 2023
- "HUD Restores 2013 Discriminatory Effects Rule," American Bar Association, Business Law Today, April 2023
- Co-author, "HUD Implements 40-Year Loan Modification Option," American Bar Association, Business Law Today, Month-in-Brief, April 2023
- "Fair Credit Reporting Act Resource Guide," MBA Compliance Essentials, 2019
- "Homeowners Protection Act Resource Guide," MBA Compliance Essentials, 2019
- "Recent Developments in PACE Financing," 74 Bus. Law. 519, 2019
- "Consumer Complaints Resource Guide," MBA Compliance Essentials, 2016
Presentations
- "Equity Solves Problems Debt Cannot - Home Equity Access Programs", ABA Consumer Financial Services Committee Business Law Section, Winter Meeting 2026 (January 26, 2026)
- "Mortgage Law Today Web Show,” Chrisman Commentary, December 16, 2025
- "The New Reality of Regulation and Enforcement,” 24th Annual Consumer Finance Legal Conference, October 22, 2025
- "M&A Changes," Texas Mortgage Bankers Association (MBA) Texas Housing Summit, November 4, 2025
- "2025 MBA Compliance and Risk Management Conference," 2025 Mortgage Bankers Association (MBA) Compliance and Risk Management Conference, September 30, 2025
- "Insiders Evaluate Potential Local/Fed Regulation And Consumer Protection & What Is Being Done,” Information Management Network Home Equity Investment & Home Equity Capital Markets Conference , March 27, 2025
- "Consumer Financial Services in Review and a Look Ahead,” American Bar Association (ABA) Webinar, November 20, 2024
- "Shared Appreciation Panel," American Association of Residential Mortgage Regulators (AARMR) Annual Regulatory Conference & Training, New Orleans, Louisiana, August 7, 2024
- "Opening Remarks," 2023 CCFL Conference, Dallas, Texas, November 2, 2023
- "Fair Access to Financial Services," 2023 Consumer Finance Legal Conference, October 13, 2023
- "What is New in ESREVER? A Look at the Last Year in Reverse Mortgage Statutes, Regulations, and Events," 2023 Consumer Finance Legal Conference, October 12, 2023
- "How Lenders Can Navigate Current Economic Challenges (A Three-Part Series)," 2023 Consumer Finance Legal Conference, October 12, 2023
- "Increasing Access to Alternatives to Stick Built Housing," American Bar Association Forum on Affordable Housing & Community Development Law 2023 Annual Meeting, Washington, DC, May 25, 2023
- "U.S. Supreme Court’s Review of the CFPB’s Funding: Constitutional or Not?" Real Estate Services Providers Council (RESPRO)’s RESPRO30, Lake Tahoe, Utah, May 23, 2023
- "The Fisher Memorial Program – Impact of the CFSA Case on the CFPB," ABA Business Law Section Spring Meeting, Seattle, Washington, April 27, 2023
- "Compliance Conversations: RESPA Section 8 and Lead Generation," Mortgage Bankers Association (MBA) Legal Issues and Regulatory Compliance Conference, Austin, Texas, May 7, 2023
- "Navigating Challenges in the Current Mortgage Market," American Mortgage Conference, Isle of Palms, South Carolina, May 2, 2023
- "Regulatory Compliance Concerns in the Current Era," Manufactured Housing Institute (MHI) 2023 Congress & Expo, Las Vegas, Nevada, April 21, 2023