Profile
With a client base that spans institutional investors, private equity funds, banking institutions, mortgage lenders and servicers, consumer finance companies, fintech firms, and financial services companies, Rinaldo Martinez focuses his practice on addressing the regulatory landscape of consumer credit products, both at the federal state levels. His work necessitates delving into federal and state laws that substantively govern all aspects of consumer credit. Rinaldo also counsels on regulatory compliance issues related to commercial real estate.
As part of his practice, Rinaldo regularly navigates the complexities of Title X of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010, including advising on statutes such as the Truth in Lending Act (TILA), the Real Estate Settlement Procedures Act (RESPA), the Home Mortgage Disclosure Act (HMDA), the Fair Debt Collection Practices Act (FDCPA), and the Fair Credit Reporting Act.
At the state level, his practice covers licensing statutes, anti-predatory lending laws, qualification statutes, usury limitations, and prepayment penalty restrictions. He has deep experience advising on regulatory compliance issues involving hybrid residential-commercial real property, such as “fix-flip” properties, particularly regarding licensing obligations for this product.
Rinaldo also assists clients with developing business models in the context of regulatory compliance issues arising under state law, with a focus on bank partnerships. He also assists clients with state examinations, including negotiating findings with regulators before examination report finalization. Additionally, Rinaldo assists with secondary market transactions, including securitizations, that necessitate diligence of state licensing obligations.
Capabilities
Experience
- Advised cryptocurrency companies on state licensing matters, focusing on the applicability of state licensing laws to crypto products.°
- Assisted with ongoing examinations by the California Department of Financial Protection and Innovation, including assisting with preparation of presentations to enable the regulator to better understand clients’ business models.°
- Conducted in-person meetings with the Puerto Rico Office of the Commissioner of Financial Institutions to secure conditional licensing approvals, thwarting any interruption of business activities for the client.°
- Represented and provided counsel on structured finance, securitization, and other secondary market transactions on the applicability of related transaction parties’ licenses.°
- Analyzed and advised on proposed business models for private student loan companies in the context of licensing requirements, to enable proper buildout of corporate structures.°
- Assisted clients with navigating changes in ownership structure, including recapitalizations, and their impact on entities licensed at the state level.°
- Prepared multistate surveys summarizing and analyzing state consumer laws and potential licensing implications.°
- Reviewed examination requests, and acted as an intermediary, during examination by state regulatory agencies. Negotiated findings with examiners before the examination report was finalized, as well as identified mutually agreeable remediation actions in lieu of issuance of a formal action.°
- Reviewed English-to-Spanish translations of various consumer-facing agreements, including lease and loan agreements, to ensure compliance with federal and state consumer finance laws.°
°The above representations were handled by Mr. Martinez prior to his joining Greenberg Traurig, LLP.
- Preferred Outside Licensing and Regulatory Counsel, KikOff Lending, LLC
- Law Clerk, Liberty Mutual Group, Inc., International Division, 2010-2011
Recognition & Leadership
- Listed, The Legal 500 United States, Fintech, 2023
Credentials
- J.D., Boston University School of Law, 2011
- A.B., Princeton University, 2004
- New York
- District of Columbia
- Spanish, Native
- French, Conversational
- Portuguese, Conversational