Warren W. Traiger
Senior Counsel
Biography
Warren W. Traiger has developed a nationally recognized reputation on consumer compliance matters with a focus on Community Reinvestment Act (CRA) and fair and responsible banking issues. As Senior Counsel in the New York office of Buckley LLP, he advises clients on responding to allegations of discriminatory or unfair lending practices, including redlining and reverse redlining, and assists clients to design and implement appropriate preventative and detective controls to help avoid such claims.
Mr. Traiger argued before the U.S. Court of Appeals for the Second Circuit in Lee v. Board of Governors, a benchmark case regarding the rights of community organizations to challenge Federal Reserve Board (FRB) determinations on merger applications. He has testified before Congress and the federal banking agencies on fair lending and CRA reform, served as Special Counsel to the New York banking regulator on CRA, and advised the regulator on predatory lending regulation.
Mr. Traiger regularly assists banks and bank holding companies prepare the community convenience and needs portion of their regulatory applications to merge or acquire and helps clients respond to public comment regarding CRA and fair lending compliance. He represented a bank in its acquisition and integration of the finance arm of major automaker, directing pre-acquisition fair lending due diligence and updating the combined entity’s policies, procedures, and regulatory relations strategy. Mr. Traiger also served as an independent consultant for the New York Attorney General, overseeing compliance with that office’s settlement with a company that provides criminal background checks on prospective employees.
A prolific writer and researcher, Mr. Traiger’s research and statistical analysis of mortgage lending data has been cited in publications of the Federal Reserve Banks of San Francisco, Boston, and Dallas, the Federal Deposit Insurance Corporation (FDIC), and in testimony before the U.S. House Financial Services Committee.
Prior to joining Buckley, Mr. Traiger was Co-Chairman of Traiger & Hinckley LLP. Prior to entering private practice in 1990, Mr. Traiger was Vice President, Counsel and Director of Government Relations for the New York Bankers Association, the trade group for New York commercial banks. He has also served as Director of Legislation and Research and Special Counsel for the New York City Department of Consumer Affairs and as a New York State Consumer Protection Board official.
Mr. Traiger is entrenched in the New York legal and financial services community. He has served on the Banking Law Committee of the New York State Bar Association, as a member of the Banking Law and Consumer Law Committees of the Association of the Bar of the City of New York, and has taught as adjunct professor of Economics at Hunter College of the City University of New York. He received his J.D. from New York University and his B.A. from Cornell University (magna cum laude).
Webcasts & Speaking Engagements
CRA & Fair Lending Colloquium: Community Development Investing - Opportunities, Challenges and Trends
Warren Traiger spoke on the "Community Development Investing - Opportunities, Challenges and Trends" panel at the CRA & Fair Lending Colloquium on Tuesday, November 2016 in Las Vegas, NV. Click here to learn more about the event.
Speaking EngagementBuckley Sandler Webcast: The Community Reinvestment Act of 1977 - Examination Trends and Regulatory Developments
Buckley Sandler attorneys Warren Traiger , Jeff Naimon , and Kari Hall held a discussion designed to assist in-house legal and compliance staff in understanding regulatory developments and preparing for Community Reinvestment Act (CRA) examinations. The webcast featured remarks from Warren Traiger...
WebcastWashington Bankers Association: 2016 Northwest Compliance Conference
Warren Traiger spoke about the CRA and HMDA at the Washington Bankers Associations 2016 Northwest Bankers Compliance Conference in Seattle, Washington on Thursday, October 6, 2016. Click here to learn more about this event .
Speaking EngagementThe Long Island Business Report: Fair Banking on Long Island
Warren Traiger appeared on The Long Island Business Report on Wednesday, May 25 at 7:30PM on WLIW21, where he discussed fair banking on Long Island. Click here to learn more about the event.
Speaking EngagementBuckley Sandler Webcast: HMDA Rulemaking Update with Warren Traiger
Join Buckley Sandler attorney Warren Traiger for a discussion designed to assist in-house legal and compliance staff in understanding and preparing for the upcoming, significant changes to compliance under the Home Mortgage Disclosure Act (HMDA). Warren Traiger, a nationally recognized expert on...
WebcastBuckley Sandler Fair Lending Today 2016 Conference: HMDA Changes and Their Impact on Fair Lending and CRA Compliance
Warren Traiger spoke about “HMDA Changes and Their Impact on Fair Lending and CRA Compliance” at Buckley Sandler’s eighth annual Fair Lending Today Conference on Monday, March 14, 2016 in Washington, DC.
Speaking EngagementNew York Bankers Association Technology, Compliance & Risk Management Forum: Managing Fair Lending Risk
Warren Traiger spoke at the New York Bankers Association Technology, Compliance & Risk Management Forum on Wednesday, May 13, 2015 in Tarrytown, NY. His panel was titled, “Managing Fair Lending Challenges and Risks.”
Speaking EngagementNew York Bankers Association's Bank Counsel Seminar
Warren Traiger spoke at the New York Bankers Association's Bank Counsel Seminar on Thursday, April 23, 2015 in Albany, New York.
Speaking EngagementBuckley Sandler Fair Lending Today Conference: Fair Lending Game Changers: The CFPB's HMDA Rule and the Conflation of CRA and the Anti-Discrimination Laws
Kari Hall and Warren Traiger spoke at the firm’s 2015 Fair Lending Today Conference on Monday, March 16 in Washington, DC. Their panel was titled, “Fair Lending Game Changers: The CFPB’s HMDA Rule and the Conflation of CRA and the Anti-Discrimination Laws.”...
Speaking EngagementBuckley Sandler Webcast: CFPB Rulemaking Update
To assist in-house legal and compliance staff with planning for 2015, Buckley Sandler attorneys provided an update on recent rulemaking developments at the Consumer Financial Protection Bureau (CFPB) and the Department of Defense (DoD). The discussion will be moderated by Benjamin Olson , former...
WebcastInside Mortgage Finance Webcast: Defusing Fair Lending Risk and the HMDA Data Expansion
Warren Traiger spoke on the Inside Mortgage Finance webinar, "Defusing Fair Lending Risj and the HDMA Data Expansion," on Wednesday, December 10, 2014. Among the topics covered: What do recent fair lending actions tell you about your potential risk? How is the HMDA data expansion likely to affect...
Speaking EngagementAmerican Bankers Association Webcast: 2013 HMDA Data Update: Fair Lending and CRA Implications in the Future
Warren Traiger spoke on an American Bankers Association's webcast titled "2013 HMDA Data Update: Fair Lending and CRA Implications in the Future,” on Wednesday, November 19, 2014.
Speaking EngagementQuestSoft Webcast: The CFPB and HDMA Changes
Warren Traiger spoke on the QuestSoft webinar, "The CFPB and HDMA Changes," on Tuesday, August 29, 2014. The webinar topics covered: The Clear Intent of the New HMDA Rule Significant Rule Changes Significant Data Reporting Changes Impact on Fair Lending Issues of the Future Parts of the Rule You...
Speaking Engagement
In The News
Warren W. Traiger quoted in American Banker article, “Relief from HMDA requirements may go further than banks realize”
Warren T. Traiger was quoted on August 2, 2018 in an American Banker article, “Relief from HMDA requirements may go further than banks realize,” which discussed the Home Mortgage Disclosure Act reform and the recent clarification from a FDIC official regarding data collection for small lenders. The...
In The NewsWarren W. Traiger quoted in American Banker article, “CFPB’s Mulvaney plots HMDA rollback, but it may not matter”
Warren Traiger was quoted on May 25, 2018 in an American Banker article, “CFPB’s Mulvaney plots HMDA rollback, but it may not matter,” which discussed acting director of the Consumer Financial Protection Bureau Mick Mulvaney's remarks to scale back Home Mortgage Disclosure Act requirements,...
In The NewsWarren W. Traiger quoted in Wall Street Journal article, “Shake-up considered on how banks lend to the poor”
Warren W. Traiger was quoted on April 27, 2018 in a Wall Street Journal article, “Shake-up considered on how banks lend to the poor,” which examined the suggested rule change by the Office of the Comptroller of the Currency that would encourage banks in certain locations to lend to the poor. The...
In The NewsWarren W. Traiger quoted in American Banker article, “Reg relief = cost savings, right? Not so fast”
Warren W. Traiger was quoted on March 28, 2018 in an American Banker article, “Reg relief = cost savings, right? Not so fast,” which discussed many banks’ hope of a reduction in compliance costs should the Senate pass a bill to reform provisions of the Dodd-Frank Act. The article stated, “The...
In The NewsWarren W. Traiger quoted in S&P Global article, “Speedy bank deal sparks questions on M&A regulatory approval process”
Warren W. Traiger was quoted on February 22, 2018 in an S&P Global article, “Speedy bank deal sparks questions on M&A regulatory approval process,” which discussed the curiosity throughout the banking industry regarding whether the timeline for closing a large M&A deal could shorten...
In The NewsWarren W. Traiger quoted in PYMNTS.com article, “Banks like the Trump regulatory regime”
Warren W. Traiger was quoted on February 21, 2018 in a PYMNTS.com article, “Banks like the Trump regulatory regime,” which discussed the Trump era being defined by the lack of regulation, and noted his administration’s efforts to scale back the power of Dodd-Frank and the current motion on a bill...
In The NewsWarren W. Traiger Quoted in American Banker Article, “Five Big Questions About Mulvaney-led CFPB”
Warren W. Traiger was quoted on November 29, 2017 in an American Banker article, “Five Big Questions About Mulvaney-led CFPB,” which discussed the potential changes that are anticipated to occur with Mick Mulvaney as interim director of the CFPB. The article stated, “Mulvaney, who is also the...
In The NewsWarren W. Traiger Quoted in SNL Article, “On 40th Anniversary, Community Reinvestment Act Faces Existential Crisis"
Warren W. Traiger was quoted on October 17, 2017 in an SNL article, “On 40 th Anniversary, Community Reinvestment Act Faces Existential Crisis," which discussed the CRA origins and the belief of industry experts’ that revision is needed. The article stated, “The Community Reinvestment Act, or CRA,...
In The NewsWarren W. Traiger Quoted in Bloomberg BNA Article, “OCC Signals Path to Relaxed Community Lending Ratings for Banks”
Warren W. Traiger was quoted on October 12, 2017 in a Bloomberg BNA article, “OCC Signals Path to Relaxed Community Lending Ratings for Banks,” which discussed an important policy shift following the OCC’s regulatory bulletin on CRA ratings that could help banks avoid downgrades. The article stated...
In The NewsWarren Traiger Interviewed in the Scotsman Guide Article, "Revamped HMDA is a Game Changer"
Warren Traiger was interviewed in Victor Whitman's Scotsman Guide article, "Revamped HMDA is a Game Changer," on August 30, 2016. The Consumer Financial Protection Bureau (CFPB) published a final rule last year that greatly expanded the loan data that lenders will have to gather and report to the...
In The NewsBuckley Sandler Hosts Eighth Annual Fair Lending Today Conference
Buckley Sandler LLP hosted its eighth annual Fair Lending Today conference in Washington, DC on March 13-14, 2016. The two-day event featured an evening of interactive roundtable discussions on fair lending issues, followed by a full day of seminars. The sessions were led by Buckley Sandler...
In The NewsWarren Traiger Quoted in American Banker Article, "CFPB Takes Second Look at Its Tolerance Levels for HMDA Errors"
Warren Traiger was quoted in Kate Berry's American Banker article, "CFPB Takes Second Look at Its Tolerance Levels for HMDA Errors," on January 7, 2015. The bureau also wants to know whether the error thresholds should vary with the size of a lender's HMDA submission or with the kind of data, and...
In The NewsBuckley Sandler Announces 2016 Promotions
Washington, DC (Jan. 6, 2016) – Buckley Sandler LLP , a premier financial services, government enforcement and litigation law firm, announced today the promotion of 11 attorneys from three of the firm’s five offices, effective January 1, 2016. Katherine L. Halliday and Stephen M. LeBlanc of the...
In The NewsWarren Traiger Quoted in Law360 Article, "CFPB Data Collection Boost May Bring More Lending Cases"
Warren Traiger was quoted in Evan Weinberger's Law360 article, "CFPB Data Collection Boost May Bring More Lending Cases," on October 16, 2015. The added litigation risks do not come solely from the CFPB. The HMDA data is released publicly each year, meaning that activist groups, state regulators...
In The NewsWarren Traiger Quoted in American Banker Article, "Final HMDA Rule Still Too Costly Despite Changes, Industry Warns"
Warren Traiger was quoted in Rachel Witkowski's American Banker article, "Final HMDA Rule Still Too Costly Despite Changes, Industry Warns," on October 15, 2015. The Consumer Financial Protection Bureau backed off some of its initial plans in its final rule requiring lenders to collect more data...
In The NewsWarren Traiger Quoted in American Banker Article, "Branch Closings Could Increase Exposure in Discrimination Claims"
Warren Traiger was quoted in Jackie Stewart's American Banker article, "Branch Closings Could Increase Exposure in Discrimination Claims," on September 14, 2015. Regulators are actively pursuing discrimination claims against lenders, said Warren Traiger, a lawyer at Buckley Sandler. Banking...
In The NewsWarren Traiger Quoted in American Banker Article, "Banks' Win in NYC Threatens Cities' Reinvestment Laws"
Warren Traiger was quoted in Kevin Wack's American Banker article, "Banks' Win in NYC Threatens Cities' Reinvestment Laws," on Monday, August 10, 2015. Amid the economic fallout of the financial crisis, lots of big American cities passed local laws pressuring banks to invest more in their low-...
In The NewsWarren Traiger Quoted in Bloomberg BNA Article, "N.Y., Fearing Subprime Auto Loan Crisis, Asked to Give State Regulator Jurisdiction"
Warren Traiger was quoted in Gerald B. Silverman's Bloomberg BNA article, "N.Y., Fearing Subprime Auto Loan Crisis, Asked to Give State Regulator Jurisdiction" on Friday, April 24, 2015. The article covered remarks made by Traiger at an April 23, 2015 hearing of the New York State Senate Banks...
In The NewsBuckley Sandler Hosts Annual Fair Lending Today Conference
Buckley Sandler LLP hosted its annual Fair Lending Today conference in Washington, DC, March 15-16, 2015. The two-day event featured an evening of interactive roundtable discussions on fair lending issues, followed by a full day of seminars. The roundtables and seminars were led by Buckley Sandler...
Press ReleasesWarren Traiger Quoted in American Banker Article, "Redlining Cases Persist as Banks Adjust to Postcrisis World"
Warren Traiger was quoted in John Reosti's American Banker article, "Redlining Cases Persist as Banks Adjust to Postcrisis World," on January 21, 2015. The recent wave of redlining cases is not as flagrant as those that occurred in the 1960s and 1970s, said Warren Traiger, a lawyer at Buckley...
In The NewsWarren Traiger Quoted in American Banker Article, "What Banks Should Do to Limit Redlining"
Warren Traiger was quoted in Jackie Stewart's American Banker article "What Banks Should Do to Limited Redlining Claims" on September 17, 2014. Laws such as the Community Reinvestment Act and the Fair Housing Act are getting renewed attention from examiners, industry experts said. "Redlining is hot...
In The News
Articles & Special Alerts
"OCC Improves But Unlevels CRA Ratings" By Warren W. Traiger and Caroline K. Eisner (Banking Exchange)
On Oct. 12, the Comptroller’s Office revised its Policies and Procedures Manual to instruct examiners to limit the number of Community Reinvestment Act rating downgrades based on evidence that a bank has violated other laws. The revision is a boon to national banks and federal savings associations...
ArticlesWarren W. Traiger Authored an American Banker Article, "Regulators' Silence on New HMDA Rule is Deafening"
As banks prepare to comply with a Consumer Financial Protection Bureau rule adding new reporting requirements under the Home Mortgage Disclosure Act, much attention has been paid to how expanded data points such as “interest rate” and “credit score” will affect fair-lending compliance. But the...
ArticlesIt's a New Dawn, New Day for HMDA Reporting
On Oct. 15, 2015, the Consumer Financial Protection Bureau (the CFPB or the Bureau) issued its long-awaited final rule amending and drastically expanding the mortgage loan application data reporting requirements under Regulation C and the Home Mortgage Disclosure Act (HMDA). Lenders that are...
ArticlesConsumer Financial Services Answer Book 2016
The fifth edition of the Practising Law Institute’s Consumer Financial Services Answer Book was published this month, with 29 Buckley Sandler attorneys contributing to this leading desk reference. The 2016 edition of the Consumer Financial Services Answer Book continues to provide practitioners...
ArticlesSpecial Alert: CFPB Adopts Significant Expansion of HMDA Requirements
On October 15, the Consumer Financial Protection Bureau (the CFPB or Bureau) issued a final rule that will expand the scope of the Home Mortgage Disclosure Act (HMDA) data reporting requirements while seeking to streamline certain existing requirements. Although some of the new data points the...
ArticlesThe CFPB's Proposed HMDA Rule: "Getting It Right" in Light of Major Changes to HDMA
The Consumer Financial Protection Bureau’s (the “Bureau” or the “CFPB”) proposed rule to amend Regulation C (the “HMDA Proposal”) to implement changes to the Home Mortgage Disclosure Act (“HMDA”) will drastically expand the amount of mortgage loan application data that lending institutions will be...
ArticlesHow to Move the CRA Into the 21st Century
Warren Traiger authored "How to Move the CRA Into the 21st Century," which appeared in American Banker on November 3, 2014. There's a disconnect in the banking agencies' approach to reforming the Community Reinvestment Act. On the one hand, the Federal Reserve, Office of the Comptroller of the...
ArticlesConsumer Financial Services Answer Book 2015
Buckley Sandler lawyers played a prominent role in the publication of this leading desk reference on consumer financial services, published by the Practising Law Institute. The 2015 edition of this publication continues to provide practitioners with a core understanding of the laws governing...
ArticlesBanks Should Steel Themselves for Fair Lending Game-Changer
Warren Traiger authored, "Banks Should Steel Themselves for Fair Lending Game-Changer" in American Banker on August 12, 2014. The Consumer Financial Protection Bureau's proposal to increase the categories of mortgage data collected and reported under the Home Mortgage Disclosure Act is, in the...
ArticlesThe CRA is Not a Fair Lending Law
The ongoing regulatory emphasis on enforcing the anti-discrimination provisions of the Equal Credit Opportunity Act and Fair Housing Act has had an unintended and counterproductive consequence. It is undermining the legislative rationale of the Community Reinvestment Act and threatening its...
Articles
Education
- J.D., New York University, 1978
- B.A., Cornell University, 1975 (magna cum laude)
Admissions
- New York
Government Service
- Director of Legislation and Research and Special Counsel for the New York City Department of Consumer Affairs
- Senior Attorney at the New York State Consumer Protection Board