Overview
Tarrian L. Ellis advises banks, non-depository financial institutions, fintechs, and other financial services providers on navigating the complex regulatory landscape governing financial products and services. His practice encompasses federal and state regulatory compliance of financial products and services, licensing, product development, and supervisory matters, aligning client objectives with regulatory requirements.
Tarrian's clients include domestic and international banks, trust companies, fintechs, payment services firms, and other non-bank financial services providers. He provides counsel on various issues, including electronic lending, digital payments, mortgage lending and servicing, fair lending, and student loan servicing. He also advises on compliance with card network rules, ACH network rules, and other payment system requirements.
As a member of Steptoe's Financial Innovation & Regulation practice, Tarrian collaborates with a team experienced in traditional and digital banking solutions. The practice provides comprehensive guidance to clients implementing established and emerging financial technologies, helping them overcome regulatory, compliance, organizational, and commercial challenges in a heavily regulated industry. Tarrian also advises commercial lenders, e-commerce companies, and digital asset companies on the applicability of state and federal financial laws.
Prior to joining Steptoe, LLP, he served as a regulatory attorney with the Consumer Financial Protection Bureau (CFPB) and the New York State Department of Financial Services (NYDFS). While at the CFPB’s Office of Regulations, he participated in complex rulemaking projects, including drafting rules and guidance related to privacy, small business lending, and open banking. He also demonstrated subject matter proficiency on issues concerning mortgage servicing and disclosure, as well as electronic payments. At NYDFS, he supported chartering, licensing, permissible activities and investment oversight, supervision, and examination of state-chartered institutions.
- District of Columbia
- New York
- J.D., New York Law School
- B.P.A., Florida International University, magna cum laude, Public Administration
Areas of Work
Representative Matters
Financial Institutions
- Counseled an international bank on US market entry, including managing applications with state and federal banking regulators, and offered ongoing advice on operational compliance.
- Advised one of the largest global financial institutions in matters of liquidity covenant compliance and regulatory due diligence for loan purchases.
- Provided legal counsel for a financial institution specializing in real estate capital in matters of mortgage servicing for a major real estate project.
- Provided advice to commercial bank clients on the application and availability of relief concerning contractual obligations following the collapse of a financial institution.
- Advised a leading global investment management firm on regulatory due diligence regarding the acquisition of multi-million-dollar loan portfolios, including consumer loans, mortgage loans, and private student loans.
- Provided counsel to healthcare credit service providers on multi-state analysis of requirements regarding medical debt financing and advised on state usury limits and legislative updates regarding the servicing of medical debt.
Technology Companies
- Assisted a digital payment technology company in a multi-state analysis of money transmitter licensing requirements
- Advised a leading fintech company on a partnership with an educational institution for a BNPL student loan product.
Retailers
- Assisted retail client in preparing responses to Consumer Financial Protection Bureau civil investigative demands.
- Assisted in representing a client in an Informational Hearing before the Consumer Financial Protection Bureau.
- Provided counsel to online merchants on surcharge rules and analysis of relevant consumer financial services laws.
News & Publications
Client Alerts
State Oversight: The Next Frontier for Consumer Protection
April 9, 2025
By: Julia B. Strickland, Benjamin M. Saul, Stephen J. Newman, Andrew Owens, Juliana Gerrick, Tarrian L. Ellis, Nathaniel Sans
Publications
How Banks Can Prepare For NYDFS Overdraft Overhaul
March 19, 2025
By: Stephen A. Aschettino, Tarrian L. Ellis, Benjamin M. Saul, Andrew Owens
Client Alerts
NYDFS Proposals Target Overdraft Fees
January 27, 2025
By: Stephen A. Aschettino, Tarrian L. Ellis, Andrew Owens, Benjamin M. Saul
Client Alerts
January 17, 2025
By: Evan T. Abrams, Tarrian L. Ellis, Christopher R. Fredrich, Coy Garrison, Andrew Owens, Benjamin M. Saul
Client Alerts
CFPB Finalizes Rule on Overdraft Credit – What Financial Institutions Need to Know
December 19, 2024
Publications
CFPB Finalizes Federal Oversight of Digital Payment Apps
November 25, 2024
By: Benjamin M. Saul, Tarrian L. Ellis, Nathaniel Sans
Client Alerts
CFPB Finalizes Open Banking Rule: What Financial Institutions and FinTechs Need to Know
October 28, 2024
By: Andrew Owens, Benjamin M. Saul, Tarrian L. Ellis, Nathaniel Sans
Client Alerts
CFPB's Proposed Interpretive Rule on Earned Wage Access Products
August 12, 2024
By: Benjamin M. Saul, Andrew Owens, Vito Arethusa, Tarrian L. Ellis
Previous Employment
- Counsel, Office of Regulations, Consumer Financial Protection Bureau, 2020-2023
- Attorney, Excelsior Fellow, Consumer Examinations Unit, New York State Department of Financial Services, 2018-2020
- Specialist 92A, United States Army Reserve, 2011-2019
Professional Affiliations
- Adjunct Professor, New York Law School
- Young Lawyer Division Liason – ABA Consumer Financial Services Committee (2023 – 2025)
- Washington Bar Association (2024 - present)
- Member, New York City Bar Association (2018 - present)
- Member, Metropolitan Black Bar Association (2018 – present)
- Member, National Bar Association (2018 – present)
- Member, Kappa Alpha Psi Fraternity, Inc.