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Thomas Homberg

Thomas R. Homberg

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Thomas Homberg

Thomas Homberg is a shareholder and team leader of the firm’s Banking & Financial Institutions Practice Group. He has a broad background in financial institution regulation and formerly was an in-house attorney at a $20 billion bank holding company and acting general counsel of a federal thrift.

Thomas has extensive experience in representing banks, thrifts and other financial service companies on a wide range of regulatory, compliance and transactional matters, including strategic planning, mergers and acquisitions, charter formations, interstate branching and expansion, capital raising initiatives, secured and unsecured financings, asset securitizations, commercial lending transactions, and state and federal enforcement and regulatory issues. He also frequently counsels banks, private equity funds and hedge funds on control and other regulatory issues related to equity investments in banks and other companies.

He has a diverse regulatory practice and has represented clients on a variety of complex transactions, including bank mergers and acquisitions, joint ventures and strategic alliances, merchant banking and equity investments, cross-industry acquisitions, and asset purchases and sales involving loan, deposit, credit card, and trust and investment portfolios. Thomas has served as lead bank regulatory counsel in connection with over twenty-five mergers and acquisitions over the past ten years, including more than ten interstate bank merger transactions. He also has structured and negotiated more than twenty branch sale transactions, including the second largest branch transaction in the United States in 2007. He also specializes in transactions involving the creation of new bank charters and charter conversions and counsels clients in choosing and structuring the most appropriate bank charter for their business needs.

Thomas routinely advises clients on consumer financial service and retail banking matters, including compliance with federal and state laws and regulations governing credit cards, mortgage loans, deposit products, automobile financing and related retail products. His experience in this area includes compliance with the Truth in Lending Act, Fair Credit Reporting Act, Electronic Funds Transfer Act, Equal Credit Opportunity Act, Fair Debt Collection Practices Act and Real Estate Settlement Procedures Act. He has worked extensively with clients on data use, privacy and data security issues, and he frequently advises clients on interstate compliance matters, including interest rate exportation and federal preemption. He also represents and assists clients in creating, structuring and implementing new products and services and has helped structure a variety of interstate deposit, loan and wealth management programs. His clients include many of the largest bank holding companies in the Midwest, along with community banks, mortgage and finance companies, trust companies and other financial service providers. Thomas has extensive dealings with state and federal banking regulators, and assists clients with examination matters and informal and formal enforcement actions.

Thomas has been actively involved for many years with financial services legislative and regulatory issues. Thomas frequently speaks on financial services topics for a variety of organizations and he regularly meets with bank boards regarding strategic planning, corporate governance and other regulatory matters.

A native of Milwaukee, Thomas graduated from Marquette University cum laude with a bachelor of arts degree in Political Science and International Affairs. He received his Juris Doctor degree cum laude from Marquette Law School, where he was named to the Dean’s List. Thomas is a member of Phi Beta Kappa, the Consumer Financial Services Committee of the Business Law Section of the American Bar Association, the American Bar Association, the Wisconsin Mortgage Bankers Association and the State Bar of Wisconsin.

Representative Experience

Mergers and Acquisitions. Represented public and private banks and bank holding companies in over ten interstate bank merger transactions, the largest of which was valued at over $700 million.

Branch Transactions. Structured and negotiated more than twenty branch sale transactions, including the purchase of Fifth Third Bank's Arizona branch network involving deposits of more than $430 million, and the sale of M&I Marshall & Ilsley Bank's Oklahoma branch network involving deposits of more than $230 million.

Asset Transactions. Represented a federal savings association in the purchase of over $2.7 billion in home equity loans and lines of credit over a five-year term. Represented banks and finance companies in various purchases and sales of credit card, trust, deposit and mortgage loan portfolios.

Non-Bank Acquisitions. Represented several financial institutions in connection with preparing and filing applications with federal regulatory authorities to obtain prior approval of various non-bank acquisition and corporate expansion transactions.

Bank Note Program. Structured, negotiated and documented $7 billion bank note program. Represented bank in connection with a first-of-its-kind $475 million secured bank note guaranteed by the Federal Agricultural Mortgage Corporation.

Corporate Financings. Represented major financial holding company in over $2.5 billion in corporate financings, including a novel $400 million equity-linked note issuance program.

Capital Initiatives. Assisted a bank in establishing a REIT subsidiary as a vehicle to issue tax-advantaged Tier 1 capital.

Regulatory Interpretations. Obtained a precedent-setting waiver from the Board of Governors of the Federal Reserve regarding various aspects of Section 23A of the Federal Reserve Act.

Charter Formations. Represented several clients in raising capital and establishing state/national bank charters and bank holding companies.

Multi-State Consumer Compliance. Represented several clients in evaluating alternative structures for originating and delivering consumer and retail banking products and services, including evaluating interest rate exportation, preemption and licensing issues with respect to multi-state programs.

Securitizations. Provided counsel in connection with various mortgage and automobile loan securitization transactions involving public and private securities, including term and conduit structures.

Trust Preferred Securities. Represented several bank holding companies in connection with the issuances of trust preferred securities both in traditional offerings and to pooled structures.

Admitted To Practice

Wisconsin - 1996

Professional Associations

American Bar Association
Consumer Financial Services Committee of the Business Law Committee of the ABA
State Bar of Wisconsin
Wisconsin Mortgage Bankers Association


Named a Wisconsin Rising Star (2009)

Listed in Best Lawyers (Banking & Finance Law, 2013 - present; Financial Services Regulation Law, 2015 - 2016 and 2018 - present)


Juris Doctor, Marquette University Law School, 1996, cum laude, Dean's List, Phi Beta Kappa

Bachelor of Arts, Marquette University, Political Science and International Affairs, cum laude

833 East Michigan Street
Suite 1800
Milwaukee, WI
Cathy Zabler

Best Lawyers 2019

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