David A. Thomas

david thomas

David A. Thomas



1300 19th Street NW, 5th Floor
Washington, DC 20036-1609

David’s practice focuses primarily on federal and state regulatory and compliance matters related to the consumer financial services industry.  He advises financial institutions, mortgage lenders, servicers, investors, and other industry participants on compliance with requirements under RESPA, TILA, FDCPA, FCRA, ECOA, and the Fair Housing Act, among other requirements.  In addition, David prepares multi-state regulatory compliance surveys and analyzes matters pertaining to residential, business purpose, and commercial mortgage lending, brokering and servicing, and assists clients in preparing for, and responding to, examinations by state and federal regulators.

David also assists clients in transactions involving unsecured consumer loans, the purchase and sale of mortgage loans and mortgage servicing rights, and in developing new consumer financial products, including innovative products offering alternatives to debt financing.

Practice Areas


  • William & Mary Law School, J.D., 2009
  • University of Nebraska, B.A., with Distinction, 2006


  • District of Columbia
  • Maryland
  • U.S. District Court for the District of Columbia
  • U.S. District Court for the District of Maryland

Representative Matters

  • Conduct multi-state surveys of state data breach requirements
  • Review websites and flyers for compliance with federal and state advertising requirements applicable to licensed mortgage lenders
  • Conduct multi-state reviews of requirements applicable to lenders making business purpose and commercial loans
  • Conduct multi-state reviews of usury limitations applicable to residential, business purpose, and commercial loans
  • Review and prepare mortgage loan documents and consumer disclosures
  • Assist companies with the design and development of new consumer financial products
  • Assist mortgage lenders and servicers in preparing for examinations, and responding to examination findings, by state and federal regulators
  • Advise investors on risks involved with marketplace lending transactions
  • Review and prepare agreements for the purchase and sale of mortgage loans and mortgage servicing rights


  • Co-author, Homeowners Protection Act Resource Guide, MBA Compliance Essentials (MBA 2019)
  • Chapter contributor, Real Estate and Mortgage Banking: A New Era of Regulatory Reform (Thomson Reuters 2017-2018)


  • American Bar Association
  • District of Columbia Bar Association
  • Maryland State Bar Association