Financial Services Regulation


Contributed by Sidley Austin LLP

Financial Services Regulation Overview 

The US financial services sector is subject to extensive regulation and supervision at both the federal and state levels. The applicable laws and regulations, and the applicable regulators, depend on the specific business at issue and the type of company involved. Thus, different laws apply to broker-dealers and to banks; federally chartered banks are subject to different laws and have different regulators than do state chartered banks.

This overview highlights four key areas within this sector: broker-dealer regulation, consumer finance regulation, the Volcker Rule, and virtual currencies.

Broker-Dealer Compliance 

Broker-dealers are subject to extensive regulation at three different levels: by the SEC, by self-regulatory organizations such as FINRA and the securities exchanges, and by state securities regulators. These regulators oversee all aspects of a broker-dealer’s activities, from sales and trading practices to financial responsibility. All three levels of regulators conduct examinations of broker-dealers as well as enforcement investigations. Broker-dealers must develop and implement detailed written supervisory procedures covering all applicable laws and rules, and must implement a compliance program to test the effectiveness of those procedures.

In the wake of the financial crisis, the securities regulators have placed renewed emphasis on examinations and enforcement actions against broker-dealers, with record numbers of cases and levels of penalties against both firms and individuals. The SEC has established special enforcement units concerning market abuse, complex products and municipal securities, all of which focus primarily on broker-dealers, in addition to a broader broker-dealer task force. Both the SEC and FINRA have begun to use “big data” to review broker-dealers’ trading and recommendations to customers on a much broader basis than was ever before possible. The SEC, together with the Department of Justice, has used this data to, among other purposes, campaign against insider trading in the financial services industry. Increasingly, the SEC and other US securities regulators work with foreign securities regulators, and broker-dealers must achieve compliance with multiple countries’ securities laws.

The Dodd-Frank Act resulted in substantial new regulations on broker-dealers, especially those that are subsidiaries of bank holding companies or that trade derivatives. The JOBS Act made important changes concerning private placements of securities. The SEC is conducting a wide-ranging review of securities market structure regulations which is likely to result in new rules relating to high-frequency trading, among other issues. The SEC has adopted new rules on securities market access and financial responsibility, and has proposed new rules on computer systems integrity. FINRA is completing its harmonization of NASD and NYSE rules, including important expansions of its suitability, research and supervision rules. FINRA also has embarked on a retrospective review of its rulebook for further analysis of costs and benefits, effectiveness and efficiency. The SEC and the MSRB are implementing new rules for municipal advisers, and are considering broader reforms for the municipal market. The SEC is considering a harmonization of broker-dealer and investment adviser regulation, and the imposition of a fiduciary standard of care on retail broker-dealers. The compliance requirements for broker-dealers have never been more complex and have never changed so quickly, but the consequences of violations have never been more serious.

Consumer Finance 

The marketplace for consumer financial services has changed dramatically over the past several years, as this business was at the heart of the financial crisis and has evolved as part of the recovery.

Mortgage Lending 

At the leading edge of the changed landscape of consumer finance is residential mortgage lending. That industry has been all but reinvented in the past years, with some of the largest lenders disappearing and the secondary market now all but monopolized by Fannie Mae and Freddie Mac. The Consumer Financial Protection Bureau (CFPB), implementing the Dodd-Frank Act, has issued expansive new rules to implement changes to the Truth in Lending Act and the Real Estate Settlement Procedures Act. Among the most important changes are:

• Ability to pay underwriting rules, and the safe harbor for “Qualified Mortgages” that meet the tests set forth in the new regulations. How the market reacts to these rules, and particularly the possibility of assignee liability for some violations, could significantly shape the future of the industry.

• Limits on loan originator compensation.

• Extensive new loan servicing requirements, imposed through regulation as well as through consent decrees by the federal and state regulators with the largest loan servicers.

Credit Card Lending 

Credit card financing continues to adjust to the 2009 enactment of the CARD Act. It has also remained a target area for litigation and enforcement action. Many of the CFPB’s large enforcement settlements have involved credit cards, addressing “add-on” products marketed to cardholders and other practices. Those actions have resulted in an industry-wide examination of marketing practices and compliance generally. Credit card collection practices, and the sale of charged off debts, have also come under scrutiny, by courts, regulators and private plaintiffs.

Mobile Delivery 

The development of mobile payment products, and the delivery of all manner of consumer financial services through mobile devices, has become a significant growth area. Mobile products raise a number of regulatory and compliance issues. Key issues are the security and privacy of data, and the manner of delivery of compliant disclosures through a mobile device.

Fair Lending 

Non-discrimination law has been an important focus of the CFPB’s and other federal regulators’ efforts, as well as industry compliance concerns. The key issue has been “effects test” liability, where a lender’s practices are found to have a “disparate impact” on minorities or protected classes even though there are no directly discriminatory policies. Numerous settlements have been reached in the mortgage area, relating to allegations that discretionary pricing policies resulted in minorities paying higher rates. The CFPB has been extensively investigating the indirect auto lending area for the same issue, and the first settlement was announced at the end of 2013. The settlement does not require the elimination of discretionary pricing, although the CFPB is pushing industry to move in that direction.


The Dodd-Frank Act gave the CFPB substantial regulatory and enforcement authority to combat “unfair, deceptive or abusive acts or practices” (or “UDAAP”) by consumer financial services providers. The statute provides standards governing these terms, but not specific definitions, giving the CFPB broad latitude in their interpretation. The CFPB has thus far looked to the history of the Federal Trade Commission's application of authority regarding unfair and deceptive acts, but the term “abusive” has substantially less precedent. Most of the CFPB’s enforcement actions to date have relied upon its UDAAP authority. As a result, companies have needed to broaden their compliance focus to include not only the specific and detailed requirements of governing laws and regulations, but also the broader and somewhat more amorphous UDAAP requirements.


Hand-in-hand with the UDAAP focus is also a regulatory focus on the process and systems that financial services providers maintain for compliance. The CFPB and other regulators increasingly expect companies to maintain a robust compliance management system, or “CMS”, through which the company assesses risks and adopts policies and procedures to appropriately address those risks. Compliance training, compliance reviews, and independent audits are all parts of a CMS. Additionally, the regulators expect companies to use customer complaints as part of their compliance process – to gauge potential problems with their products and services and take proactive remedial action.

The Volcker Rule  

The Dodd-Frank Act prohibits banks and their affiliates from engaging in proprietary trading and investing in, sponsoring, or having certain relationships with hedge funds and private equity funds (a provision commonly known as the “Volcker Rule”). Final regulations implementing the Volcker Rule were released in December 2013, and give banks and their affiliates until July 2015 to bring their activities and investments into compliance. As a result of the rule’s broad application, lingering ambiguities, and emphasis on compliance programs and reporting, the Volcker Rule has become a significant compliance focus for banks and their affiliates, and for funds with bank investors.

Virtual Currency  

The regulation (or lack thereof) of virtual currency emerged as a leading issue in the payments business during the past year. Federal and state regulators and legislators alike have been challenged to understand the implications of new forms of virtual value exchange from a wide range of perspectives, including anti-money laundering regulation, state money transmitter licensing, taxation, and securities and commodities regulation.

Due to the number of tables in this section, the editorial is in alphabetical order by firm name.

Financial Services Regulation - Nationwide


Basic facts about the department
Key office is Washington, DC.

What the team is known for Utilizes an international platform to assist both US clients with foreign broker-dealer issues and foreign clients with broker-dealer work in the USA. Acts for a variety of financial institutions on the full range of broker-dealer and securities compliance and regulation.

Strengths (Quotes mainly from clients)
"They've been really great, and we're really happy. They are very talented lawyers, very responsive and have a really good work product."

"What they do as a practice is take the time to understand the business of the institutions they are dealing with. They give advice which makes sense under the framework in which you work."

Work highlights Acted as independent consultant, as mandated by the Financial Industry Regulatory Authority (FINRA), to perform a full review of the policies and procedures of David Lerner Associates relating to the markups and markdowns of collateralized mortgage obligations, municipal bonds and nontraded REITs.

Notable practitioners  

Christopher Salter is regarded by commentators as an "extremely knowledgeable" practitioner who "provides thoughtful and thorough advice." His practice focuses on the representation of broker-dealers in regulatory compliance issues.

Washington, DC managing partner Barbara Stettner handles financial regulation and compliance on behalf of both domestic and international clients. According to one impressed client, "she is one of the most responsive attorneys I've ever worked with and she's very friendly and easy to work with."

Significant clients Bank of America Merrill Lynch, BNP Paribas, HSBC, RBS, Société Générale.

Basic facts about the department
Key offices include New York and Washington, DC.

What the team is known for Maintains a longstanding reputation in the banking regulation space and a growing presence in consumer finance. Strong in all disciplines, including compliance, enforcement and investigations. Regularly advises leading banks, insurance companies and credit unions.

Strengths (Quotes mainly from clients)
"The attorneys at A&P with whom I’ve worked do a truly excellent job at representing their clients. They have deep subject matter knowledge specifically in the area of fair lending and more generally with regard to regulations related to consumer lending in the United States. They have demonstrated an ability to consistently achieve positive results for their clients in matters that involve potentially severe monetary and reputational damages."

"The firm provided a high level of client service, high quality of advice and high level of knowledge in the financial services sector."

Work highlights Advised State Farm Insurance on significant ongoing federal regulatory changes, most recently the proposed implementation of Dodd-Frank and Basel III capital rules and their implications for the insurance industry.

Continued to advise Woodlands Commercial Bank and Aurora Bank, indirect subsidiaries of Lehman Brothers Holdings, on a broad range of issues stemming from the Lehman Brothers bankruptcy. Recently oversaw Woodlands' conversion to a non-bank uninsured state corporation, following steps which culminated in the approval of the Utah Department of Financial Institutions and FDIC of the bank's new designation.

Notable practitioners  

One impressed source reflects market opinion in saying "on enforcement matters, I'd certainly call" Richard Alexander. With his previous experience at the OCC, Alexander has become an indispensable adviser to individuals, boards and financial institutions on sensitive enforcement and investigation matters.

Kevin Barnard is singled out by clients for his strong relationships with key regulators and is lauded as "an excellent negotiator and an excellent draftsman." He leads on some of the team's biggest compliance matters, including advising Banco do Brasil on building up its operations in the USA and establishing a nationwide financial services platform.

Patrick Doyle is one of the most highly respected practitioners in the banking compliance space, thanks to impressive experience working for various government bodies and his track record advising key financial services clients during his time in private practice. His recent work includes advising State Farm Insurance on Dodd-Frank and Basel III compliance issues.

Consumer finance expert Michael Mierzewski remains a client favorite for both compliance and litigation. One source enthuses: "He is completely up to date on the constantly changing regulatory landscape, responding promptly and fully to meet client needs and making sure that his advice is compliant with both the short-run needs and long-term goals of the clients."

Brian McCormally's enforcement expertise is noted by sources around the market, who have "nothing but positive things to say" about his work. McCormally has been key in the firm's representation of Lehman Brothers Holdings' indirect subsidiaries, Woodland Commercial Bank and Aurora Bank.

Howard Cayne recently worked alongside Patrick Doyle in advising State Farm on several complex regulatory matters. His skills as a litigator are praised by numerous commentators, with his reputation for preemption cases standing out in particular.

David Freeman is another of the firm's esteemed banking compliance experts. He was a member of the team advising Federated Investors on a wide range of issues related to Dodd-Frank compliance. 

Sources agree that John Hawke is a "distinguished senior statesman" who offers clients access to superb market knowledge and experience on enforcement matters.

Michael Mancusi is praised for the "very thorough" approach he takes to diverse banking regulatory matters such as compliance and sanctions. He is characterized by one source as a "fine enforcement lawyer." Mancusi recently joined the team from Kilpatrick Townsend & Stockton LLP.

Significant clients Charles Schwab, Danske Bank, Itaú Securities, Banco de Crédito de Perú.

Basic facts about the department
Key offices include Philadelphia and Washington, DC.

What the team is known for Maintains a huge reputation in the consumer finance arena, with a strong pool of talent in both regulatory compliance and litigation matters. Noted expertise pertaining to the Consumer Finance Protection Bureau (CFPB), with particular specialties relating to the credit card and auto finance spaces.

Strengths (Quotes mainly from clients)
"They have taken a leadership role in providing resources to understand the changes in consumer finance regulations over the past four or five years."

"A terrific team." 

"It is one of the most knowledgeable firms in the areas that I work in."

Work highlights Successfully defended JPMorgan Chase in a putative class action alleging the bank's failure to provide post-repossession disclosures relating to auto finance.

Advised the Mortgage Bankers Association in relation to mortgage rulemaking by the CFPB.

Notable practitioners  

Alan Kaplinsky co-heads the firm's consumer financial services group and is widely considered to be one of the nation's most prominent consumer finance authorities. Sources attest that he is "very smart, very capable, and a very effective attorney in this field."

The "outstanding" Christopher Willis is noted for his representation of consumer finance clients in enforcement actions and litigation. In the words of one impressed interviewee, "he thinks about his clients. Not only does he have the answer, he has relevant caselaw. He can immediately translate that into what's a good practice for you."

Jeremy Rosenblum co-heads the team alongside Alan Kaplinsky, and is recognized for his prominence in consumer finance litigation. Market observers describe him as "a very fine attorney."

Richard Andreano is steadily developing a fine reputation in the consumer finance space, routinely advising clients in the mortgage space on regulatory compliance matters. Interviewees attest that he is "incredibly well regarded" within the mortgage industry.

Mark Furletti is an associate who is tipped for an impressive future by market observers. His area of focus is state and federal consumer lending laws.

Significant clients Bank of America, Discover Financial Services, Wells Fargo, TD Bank, Sallie Mae.

Basic facts about the department
Key offices include Dallas, Houston and New York.

What the team is known for Recognized for its full-service offering in the broker-dealer compliance and enforcement space, while also drawing praise for its notable financial institutions transactional capabilities. Fields a dedicated banking practice which works alongside attorneys whose expertise in diverse areas such as tax and litigation ensures the firm's ongoing popularity with clients.

Work highlights Acted for Texas-based Prosperity Bancshares on its stock and cash acquisition of American State Financial.

Represented DFW Capital Holdings in its full bank purchase of Texas-based Schwertner State Bank.

Notable practitioners  

Dallas-based Sanford Brown has earned a strong reputation for his work advising financial institutions on a range of regulatory and transactional matters. He is described as a "timely, smart and creative" attorney who is "always looking for practical business solutions."

Julian Rainero is held out by one source as being "one of the smartest broker-dealer lawyers I've ever met," and handles a range of regulatory compliance matters for clients in this space. His "encyclopedic knowledge of the law and regulations" is particularly commended, as is his "real depth of understanding of the business side of matters."

William Luedke heads Bracewell's financial institutions group, and tackles all aspects of M&A involving clients in this space. His wide-reaching regulatory and transactional expertise is commended by clients, as is his ability to bring creative solutions to matters. One source stated: "It is a privilege and a pleasure to work with him."

Significant clients Credit Suisse, FGI, Nomura, B2B Holdings, United Community Bank.

Basic facts about the department
Key office is Washington, DC.

What the team is known for A highly impressive presence in the financial services regulation field, with core excellence in the consumer finance space complemented by recognized strength in handling regulatory enforcements and investigations, often with respect to the CFPB. Enviable client roster includes the cream of the banking, mortgage and credit card communities.

Strengths (Quotes mainly from clients)
"Extremely responsive, very competent and very reliable. They are very good to work with on large-scale, detailed projects."

"Their expertise is such that we're sure we are getting the best advice. The people are specialist and focused: they get us the right answer in a technical area, and they get us there faster."

What's new? Two highly rated attorneys, Richard Gottlieb and Walter Zalenski, recently joined the team from Dykema Gossett and Weil, Gotshal & Manges respectively.

Work highlights Acted for Discover in connection with a joint investigation by the CFPB and Federal Deposit Insurance Corporation (FDIC) into alleged unfair and deceptive sales practices relating to sale protection products.

Successfully defended RBS Financial Products in a putative nationwide class action alleging violations of the Truth in Lending Act.

Notable practitioners  

Andrew Sandler is widely considered to be one of the leading stars of the financial services regulatory firmament, routinely providing regulatory advice pertaining to compliance and enforcement matters and displaying ongoing excellence in consumer finance litigation. Sources describe Sandler as "preeminent" and "an industry leader."

Benjamin Klubes is described by admiring peers as "a truly outstanding lawyer with very good judgment." He recently defended Barclays Capital Real Estate in connection with a purported class action concerning mortgage servicing activities.

Walter Zalenski is "an outstanding lawyer" in consumer finance regulatory matters, say sources. His expertise spans a range of areas, including credit cards, auto finance and mortgage lending.

Jeffrey Naimon is recognized for his strength in consumer finance regulatory compliance work. Sources attest that he is "very, very bright and thoughtful."

California-based Clinton Rockwell continues to impress in the consumer finance space. Recent work includes advising a range of financial institutions in connection with the CFPB's implementation of mortgage rulemaking under the Dodd-Frank Act.

The "terrific" Joseph Kolar enjoys an outstanding reputation as one of the nation's leading attorneys for the provision of consumer finance regulatory compliance advice.

New addition Richard Gottlieb bolsters the team's strength in the consumer finance litigation sphere. His clients include banks, mortgage lenders and auto finance companies.

John Kromer is a "very balanced, strong lawyer," say sources. He is particularly respected for his advisory work relating to mortgage regulatory compliance.

Founding partner Jeremiah Buckley is one of the most experienced and respected consumer finance attorneys in the USA. Commentators refer to Buckley as "a terrific individual" who is "one of the deans of the Bar."

Jonice Gray Tucker is identified by market observers as a rising star of the financial services enforcement sphere. She is most closely associated with her work before the CFPB, and is described by sources as "very knowledgeable in the area" and "very defense-oriented in terms of thinking about the risks."

Significant clients JPMorgan Chase, RBS, HSBC, GE Capital, Citizen's Financial Group.

Basic facts about the department
Key office is New York

What the team is known for An expert broker-dealer shop known for its impressive Dodd-Frank expertise. Works in tandem with the firm's leading derivatives transactional practice to provide high-quality, comprehensive coverage in that space. Growing reputation in banking compliance, with an especially impressive foothold among foreign banks operating in the USA.

Strengths (Quotes mainly from clients)
"Overall I think they're terrific - I've had very positive experiences. They're responsive, accurate and not overly conservative."

"I think they're one of the few firms who have really been expanding in financial services regulation and these guys have done it the right way."

Work highlights Continued to act for JPMorgan Chase, as well as Wells Fargo, Citibank and others, as primary outside counsel on swap dealer compliance, relying heavily on the team's tremendous Dodd-Frank expertise.

Advising numerous banks, such as Standard Chartered and the Development Bank of Singapore, on Volcker Rule compliance and the rule's impact on these global financial organizations.

Notable practitioners  

Transactional and regulatory specialist Steven Lofchie is a top choice for derivatives clients seeking the gold standard for all of their legal needs. Clients universally laud him as the thought leader in this space, saying: "The paper he published on what is a derivative for those of us on the banking side was perfect, absolutely perfect." Lofchie has long been sought out by leading institutions like JPMorgan Chase and Morgan Stanley for his superlative understanding of broker-dealer regulations.

Maurine Bartlett is noted for her expertise in both compliance and enforcement. Clients say she is their go-to source for SEC and FINRA questions, and describe her as "very good, very thorough and knowledgeable."

Significant clients Bank of America Merrill Lynch, BlackRock, ISDA, ING, Deutsche Bank.

Basic facts about the department
Key offices include New York and Washington, DC.

What the team is known for Enduring excellence in the financial services arena, with outstanding consistency across a broad range of areas. Market-leading practice advising systemically important financial institutions on the full range of compliance requirements that continue to emanate from Dodd-Frank and the Volcker Rule. Powerful representation of financial services clients with respect to investigations and enforcement actions by regulators. Highly respected presence in the broker-dealer space with respect to cutting-edge engagement with SEC and FINRA rulemaking and enforcement. Impressive track record with respect to transactional matters, with a long history of handling the most complex domestic and cross-border M&A in the financial services space.

Strengths (Quotes mainly from clients)
"We think they are a leader in this area, and definitely one of the best, if not the best. They have really brilliant lawyers and the caliber of work is outstanding. They're highly regarded by the regulators, who value their analysis and opinion, which makes it important to us because we understand that if we have a question, we have the regulator's ear."

"I consider them to be at the top of the totem pole in terms of firms advising financial institutions. They're very well respected by the folks on the Hill and very well respected by regulatory agencies."

"They're one of our go-to, bet-the-firm type law firms. We get great service from them. They are smart guys and gals: practical thinkers who allow us to conduct our business in the sense that where there's not a ton of clarity from the regulators there's a level of practicality and a risk spectrum that they bring to their analyses of issues."

Work highlights Advised the Institute of International Bankers in connection with a host of issues arising from Dodd-Frank, the Volcker Rule and Basel III.

Represented Bank of America in connection with an SEC investigation into its merger with Merrill Lynch and the payment of employee bonuses by Merrill Lynch.

Represented Bank of America in the sale to Julius Baer Group of its non-US wealth management business. The complex transaction involved the sale of shares and assets across 20 jurisdictions.

Represented numerous broker-dealer clients in FINRA investigations concerning matters including wash sales activity, algorithmic trading strategies and the 2010 Flash Crash.

Notable practitioners  

Robert Tortoriello is one of the most prestigious names in the US financial regulatory firmament, offering banking clients outstanding support in compliance and enforcement matters, in addition to his recognized strength in transactional matters. Sources note that he has "a very firm grip on the underlying law and how it impacts the rest of our businesses." He recently advised the Kingdom of Belgium in connection with the US regulatory aspects of its acquisition of Dexia Belgium.

The hugely well-regarded Derek Bush is a regulatory attorney who routinely advises banks and other financial institutions on ongoing operational compliance issues and M&A matters. Sources affirm that he is "very attuned to the regulatory sphere" and that "he takes the broader view on things so any advice he gives is always in context."

The "first-rate" Michael Krimminger continues to impress commentators with his acumen in the banking regulatory compliance space. He has recently been involved in advising clients on matters stemming from the proposal by the Federal Reserve regarding the restructuring of foreign bank regulation in the USA.

Former SEC general counsel Giovanni Prezioso is one of the firm's heavy hitters in the securities and broker dealer spheres, handling both compliance and enforcement matters for clients. Sources note that his assistance is "invaluable in terms of bringing the SEC perspective to a client," and attest that he "brings great credibility to the table."

David Aman advises broker dealer-clients on regulatory compliance issues, and is described by interviewees as "very careful and methodical when doing an analysis of the issues and interpreting the regulations."

Significant clients Credit Suisse, Bank of America, BNP Paribas, Securities Industry & Financial Markets Association (SIFMA), UBS.

Basic facts about the department
Key office is Washington, DC.

What the team is known for Offers leading expertise on banking regulations, with some of the most highly regarded practitioners in the country. Enforcement matters for leading financial institutions are singled out by numerous sources as the jewel in the team's crown.

Strengths (Quotes mainly from clients)
"Just fabulous. We rely on them very heavily for their opinions and advice. They really understand what we're trying to do, so they can be much more of a business partner for us. They understand the nuances of complex relationships and they can really give great business advice in addition to legal advice."

Work highlights Advising Invesco on regulatory issues related to the sale of part of its trust company, following which Invesco applied for a de novo national trust bank charter to cover the portion of the business it retained. The firm also advised on the new entity's application to the FDIC for federal deposit insurance.

Acting for the former IndyMac Bank CEO, Michael Perry, in several cases brought by the SEC and FDIC, which resulted in favorable settlements. Additionally, Perry did not receive any adverse rulings on any of the underlying merits of the cases.

Notable practitioners  

Clients say bank compliance expert John Dugan is "a superstar. The depth of his knowledge and understanding of the complex regulatory framework that governs systemically important banking institutions is unparalleled." He is singled out by peers and clients as a bellwether in the regulatory industry and recently led the team advising SIFMA and the American Bankers Association (ABA) on drafting industry comments on Basel III implementation. 

"Tremendous" investigation and enforcement specialist Jean Veta earns enthusiastic and unanimous praise from clients. She is singled out for her ability to establish an excellent rapport with boards, "earning everyone's respect." Clients also praise her commercial sense, saying: "Her real strength is business advice; she navigates very complicated issues and is able to offer a view and an opinion. She's very attuned to what her client is looking for and very comfortable in a partnership role."

Sources appreciatively note the breadth of Stuart Stock's expertise in banking regulation and also praise his work on related litigation. His recent highlights include representing Wells Fargo in a substantial Federal Reserve Board investigation and implementation of a consent order. Stock is described as a "very fine lawyer" who "knows his stuff."

Mark Plotkin has a unique and highly regarded practice, with particular expertise on the intersection between technology, privacy and banking compliance. He is also one of the country's foremost Committee on Foreign Investment in the United States (CFIUS) experts and, as such, is a key draw for international banking clients.

Ed Yingling's specialized background in trade association and political relations makes him an important strategic tool in Covington's belt. Peers praise his levelheaded approach and applaud the way he has established himself in private practice since leaving the ABA.

Rising star Keith Noreika enters the rankings following rave reviews of his strength in banking regulatory work. One happy client states: "Keith has superior judgment in dealing with complex regulatory, banking and business issues. He is always there to help us - at a moment’s notice and at any time of day or night."

Significant clients PNC, GE Capital, Citi, Wells Fargo, Brown Brothers Harriman.

Basic facts about the department
Key offices include New York and Washington, DC. 

What the team is known for A perennial name on any shortlist of the giants of the financial services regulatory sphere. Outstanding offerings in the banking and broker-dealer regulatory compliance spaces are mirrored by impressive enforcement capabilities and recognized excellence in handling M&A work in the financial services sector. Continues to be active at the forefront of regulatory developments, with a client list that reads like a 'who's who' of the industry.

Strengths (Quotes mainly from clients)
"They are a consistently solid source of advice and they are very professional. I rely on them considerably, and I consider them to be among the elite law firms in this space. I go to them for matters of material significance and for matters that warrant that level of expertise and quality."

"Their research writing and analytical ability is second to none. They do a wonderful job of partnering with my in-house lawyers. They understand the significant money at issue and strike the perfect balance with us in terms of managing the matters."

"They are outstanding. A five-star firm." 

"They're top of the class. They're a fantastic firm. They're incredibly solid, very thoughtful and they've got a top-of-the-industry expert for any issues that come up."

Work highlights Advised 22 systemically important US bank holding companies and foreign banks with respect to 'living wills', as stipulated by Section 165 of the Dodd-Frank Act.

Represented Italian bank Intesa Sanpaolo in connection with DOJ and Office of Foreign Assets Control (OFAC) investigations into alleged violations of US sanctions concerning Iran, Cuba, Libya and Sudan. Following investigations by the firm and presentations to the authorities, the bank settled the matter for $2.9 million, a small fraction of the settlements agreed by other investigated banks.

Counseled numerous key players in the broker-dealer industry, including The Bank of New York Mellon and Citi, on a range of matters stemming from Dodd-Frank including the Volcker Rule, the 'Swaps Pushout' Rule and OTC Derivatives Reform.

Advised Rabobank on the US aspects of the sale of 90.01% of the equity in Robeco Groep to ORIX.

Notable practitioners  

Former SEC Commissioner Annette Nazareth is considered to be a leading star in the broker-dealer space, and has played a key role in keeping the firm's clients apprised of regulatory developments in this area. Commentators laud her "excellent advice and decisive, broad practice."

Randall Guynn is widely considered to be one of the leading financial services regulatory attorneys in the USA. Sources attest that he "has his finger on the pulse" of regulatory developments, with one banking client affirming that "he is keenly aware of our issues and conventions and has a very commercial perspective." Guynn is equally comfortable providing regulatory compliance advice and navigating M&A transactions in the financial services space.

Margaret Tahyar is "a brilliant lawyer and really tireless," and "an intellectual leading light," say sources. She is noted for her expertise in regulatory compliance matters for banking clients, and is commended for her knowledge of a host of matters, including 'living wills' rules under Dodd-Frank.

Luigi De Ghenghi handles banking compliance and M&A matters for clients such as Morgan Stanley, Lloyds and Rabobank. Sources describe him as "extremely knowledgeable about the bank regulatory space."

Lanny Schwartz continues to be recognized among the leading broker-dealer regulatory compliance lawyers in the USA. He provides ongoing regulatory advice to key industry players such as SIFMA.

George Bason is a lauded M&A attorney with strong experience of transactions in the financial services space.

Significant clients Citi, Deutsche Bank, Lloyds Banking Group, Credit Suisse, Rabobank.

Basic facts about the department
Key offices include New York and Washington, DC.

What the team is known for Handles a wide range of financial services issues, with expertise in banking compliance and regulatory enforcement and related M&A transactions involving significant financial institutions. Able to offer advice to financial industry clients both at home and abroad thanks to the firm's international presence across Europe and Asia. Clients include banks, trusts and insurance companies.

Strengths (Quotes mainly from clients)
"They have a very practical, business-oriented approach with a deep knowledge of US and foreign regulations. I see them as trusted advisers for me and my company."

"They have very knowledgeable and intuitive lawyers. Their advice is always infused with the realities of our business, which we appreciate very much."

Work highlights Advised a series of prominent insurance industry clients, including Prudential Financial and Northwestern, on a series of matters relating to the implementation of Dodd-Frank.

Acted on behalf of Markel on its acquisition of Bermuda reinsurance provider Alterra Capital Holdings, a transaction worth in excess of $3 billion.

Represented AIA Group in the acquisition of ING's Malaysian insurance business for $1.7 billion.

Notable practitioners  

Paul Lee is particularly involved in legislative issues relating to banks and the implications of Dodd-Frank. He earns particular praise from clients for the depth of his intellect and is described as "a brilliant man and a very good practitioner."

"Very thorough and professional lawyer" Gregory Lyons is highly rated by clients for his business-oriented approach and strong communication skills. He serves as cochair of the firm's financial institutions group and focuses on transactional and regulatory issues.

Practice cochair Satish Kini represents financial institutions both in the USA and abroad in regulatory compliance and enforcement as well as banking transactions. According to clients, "he is an analytic person but on top of that he is thoughtful in a way that brings his analytic nature to a successful conclusion."

Nicholas Potter focuses his practice on corporate transactions involving the insurance industry, including M&A, capital markets and financing deals. He also acts for significant private equity firms and investment banks.

The "absolutely outstanding" John Vasily earns respect from clients as a strong corporate practitioner. He handles M&A involving the financial services industry both domestically and abroad, with expertise in the Asia and Latin America markets.

Significant clients American Express, Fifth Third Bank, JPMorgan Chase, Morgan Stanley, RBS Citizens.

Basic facts about the department
Key office is Washington, DC.

What the team is known for Broad banking and financial institutions practice which has expertise in all areas of banking compliance, enforcement and investigation work as well as experience in M&A transactional work in the financial services space. Regularly advises on important legislative issues including the application of Dodd-Frank and the Volcker Rule.

Strengths (Quotes mainly from clients)
"They are very knowledgeable about the subject matter but beyond that they are very much familiar with the interpersonal and political dynamics driving the decisions on regulatory reform."

"I think it's a very well-run firm. The lawyers I deal with directly are very intelligent and creative thinkers in trying to find a solution."

Work highlights Acted for e-trade investor Citadel on a range of issues relating to banking regulation and securities compliance.

Represented the American Bankers Association in relation to its application of new qualified mortgage and ability-to-repay rules made by the Consumer Financial Protection Board.

Advised Idaho corporation Western Capital on its acquisition of Northwest Bank.

Notable practitioners  

Department head Thomas Vartanian is known as "one of the best in the space" thanks to his all-around expertise in financial services regulation. According to clients, "he has a very good grasp of what is going on in banking and the things that affect us."

Robert Ledig is regarded by financial institution clients as a "zealous advocate and creative strategic thinker." He has extensive expertise across the full range of banking matters, including investigations, regulatory compliance and enforcement.

David Ansell is a "good, strong practitioner," according to market commentators. He is held in high regard by clients for his practical, thoughtful and detail-oriented approach to M&A transactions involving financial institutions.

Significant clients Paulson & Co., Silver Point Capital, Federal Home Loan Bank System, Hawaiian Electric Industries, Kennedy-Wilson.

Basic facts about the department
Key offices include New York, Boston and Washington, DC.

What the team is known for A widely praised consumer finance litigation practice used by major clients for contentious work, as well as a broad range of compliance matters, both in consumer finance and banking.  Also experienced in banking M&A, particularly among large Northeastern clients. Represents leading regional, national and international financial institution clients.

Strengths (Quotes mainly from clients)
"A very strong team of lawyers. Goodwin Procter excels at oral and written advocacy. They're good strategic thinkers and also have a very good knowledge of our company and the industry as a whole."

"They were very responsive and had the appropriate number of people to facilitate the transaction. They were able to bring in a broad range of expertise for various aspects of the transaction and were very well coordinated in their approach. They have a broad, high level of business and legal expertise."

Work highlights Advised a leading UK-based financial institution on the regulatory issues associated with offering financial services and products in the USA, including licensing under state and federal law.

Represented major financial institutions, including Bank of America and Wells Fargo, in five separate consumer finance multidistrict litigation cases. The cases involve issues such as subprime and discriminatory lending.

Notable practitioners  

"Fantastic consumer finance lawyer" Lynne Barr has one of the foremost consumer finance compliance practices in the country and is also recognized for her excellence in banking compliance. Her recent highlights include representing Republic Bancorp in one of its subsidiaries' purchase of some of the assets and most of the deposits of H&R Block Bank.

Numerous sources sing the praises of Thomas Hefferon, one of the "preeminent litigators in consumer financial practice." He has tremendous experience advising major financial institutions in consumer finance litigation and, according to his clients, is "intelligent, strategic and a very strong oral advocate with a commanding style."

William Mayer is a client favorite for complex financial institution M&A work. Based in Boston, he is one of the most respected names in the Northeast and impresses on deals like Eastern Bank's acquisition of Campello Bancorp. One client enthuses: "He stays abreast of every single thing I have going on with his firm and then some. He's just always available; even if it's not a legal-related matter he's always available to talk me through what my thought process is and how I should be handling it. An overall excellent adviser."

Regina Pisa is the firm's chair and one of its leading names for financial institutions M&A. She is one of the nation's most experienced practitioners in this arena and has represented many household-name financial institutions in major M&A deals.

William Stern's banking compliance expertise is praised by several commentators, who note that he is "very good for pure regulatory work." His recent activity includes advising a money center bank on the Volcker Rule's application to some of the bank's real estate funds.

Significant clients Quicken Loans, Brookline Bancorp, American Express, TD Bank, Morgan Stanley.

Basic facts about the department
Key offices include New York and Washington, DC.

What the team is known for Identified as a highly active regulatory compliance and enforcement offering, whose ability to provide a full-package financial institutions service sees it act for a national and international client base. Also maintains a strong transactional presence, offering particular skills in the community bank arena.

Strengths (Quotes mainly from clients)
"They do great work, and truly understand the business perspective as well as the legal perspective."

Work highlights Acted for New Hampshire Thrift Bancshares on the regulatory aspects of several transactions, including the acquisition of Charter Trust Company and of The Nashua Bank.

Represented Alliance Financial during its $233 million purchase by NBT Bancorp.

Notable practitioners  

Global corporate practice co-head Stuart Stein is acclaimed for his expertise across a range of regulatory and transactional matters that impact financial institutions, regularly representing clients in areas such as enforcement and corporate governance. His "very sound judgment around the thornier issues" is particularly highlighted by sources, who also note that "he is a walking encyclopedia of knowledge and seems to have gone through everything before."

Richard Schaberg is described by one client as "a rockstar in financial services law," and co-heads the firm's global financial institutions group. He is particularly highlighted for his regulatory compliance practice, and is praised for the "great amount of knowledge and expertise" he brings to his practice.

Significant clients Western Alliance Bancshares, Webster Bank, CNB Financial, Westfield Bank, Opportunity Bancshares.

Basic facts about the department
Key office is Hannover, MD.

What the team is known for Consumer finance and privacy law specialists assisting clients with the full range of financial products, including issues relating to mortgage lending, property leasing and credit cards.

Strengths (Quotes mainly from clients)
"An excellent regulatory and compliance firm." 

Notable practitioners  

Robert Cook is deeply respected in the market for his longstanding experience and extensive knowledge of the practice area. He represents banks, credit unions and other financial institutions in a series of major consumer finance programs.

Thomas Hudson focuses on consumer finance issues on behalf of a number of financial services clients. He is a well-renowned practitioner among his peers in the market.

Basic facts about the department
Key office is Washington, DC.

What the team is known for Maintains an outstanding reputation in the consumer finance space, most notably with respect to the mortgage industry. Impressive bench strength offers clients expertise in compliance with CFPB and Federal Housing Administration (FHA) regulations and consumer finance litigation. Other areas of excellence include auto finance, credit cards and student loans.

Strengths (Quotes mainly from clients)
"They are excellent. They are really good in terms of dealing with the enforcement arms of agencies. They will search for and use every advantage that the client has. They are also very attuned politically."

"They are very responsive and provide quality legal services."  

"The gold standard." 

Work highlights Acted for Wells Fargo on its $25 billion foreclosure settlement with the federal government.

Advised Bank of America on compliance with regulations affecting the origination and servicing of government insured and guaranteed residential mortgage loans.

Notable practitioners  

Laurence Platt continues to be considered a national leader in the consumer finance sphere, most notably with respect to the mortgage space. Sources describe him as "practical, commercial and very responsive," while one interviewee maintains that he is "a master of the mortgage business." Among recent matters, Platt represented Wells Fargo in its $25 billion global foreclosure settlement with the federal government and 49 state attorneys general.

Susan Grafton enjoys a solid reputation in the broker-dealer sphere, offering an impressive list of clients compliance advice and expert representation in enforcement matters before the SEC and FINRA. Sources affirm that she is "a very talented lawyer." 

Melanie Brody is a consumer finance regulatory compliance expert with a focus on fair lending matters at both state and federal level. She recently acted for CoreLogic on a businesswide review of its operations and products to ensure compliance with CFPB initiatives. One impressed interviewee describes Brody as "a next-generation superstar in this space."

Steven Kaplan heads the firm's financial services group. He has played a key role in the firm's relationship as regulatory and transactional counsel for American Express in relation to its reloadable card program with Walmart. Sources say he is "very knowledgeable on the subject matter and very strong."

Phillip Schulman is considered to be one of the nation's leading attorneys for matters pertaining to the Department of Housing and Urban Development (HUD). Sources attest that "he has a very good connection to the agencies in Washington, DC."

Significant clients American Express, Bank of America, EverBank, MetLife, Wells Fargo.

Basic facts about the department
Key office is Washington, DC.

What the team is known for Increasingly recognized as a significant player in this space, housing a sizable bench of dedicated regulatory and transactional financial services attorneys. Brings together broad-based experience across a range of corporate, compliance and securities matters when handling a significant volume of M&A for financial institutions.

Strengths (Quotes mainly from clients)
"The service is very good: prompt, thorough and reliable. The knowledge of the sector is also extremely high."

"They are very good at getting the right partner's expertise to us, whatever the topic."

Work highlights Represented SI Financial Holdings in its $61.3 million purchase of Newport Bancorp.

Advised Community Financial Shares on its recapitalization, involving its $24 million stock sale to various investors.

Notable practitioners  

Gary Bronstein heads the firm's financial institutions team and is a key contact.

Significant clients Cordia Bancorp, Beneficial Bank, Mayflower Bancorp, ECB Bancorp, Piedmont Community Bank Holdings.

Basic facts about the department
Key offices include New York and Washington, DC.

What the team is known for Demonstrates impressive regulatory compliance capabilities when acting in the broker-dealer arena, drawing on deep-rooted expertise in nationwide and global matters impacting financial institutions. Maintains an impressive client portfolio, attracting leading industry names thanks to its cross-border expertise, corporate strength and litigation skills.

Strengths (Quotes mainly from clients)
"I have a very good impression of their performance, responsiveness, deep experience and knowledge."

"The firm has very good client service and its knowledge of this sector is excellent."

Work highlights Handled the registration of a clearing agency dealing with security-based swaps on behalf of client MarkitSERV.

Acted for JPMorgan Securities and Jefferies Finance as the lenders in the negotiation of a loan credit facility for trading platform operator Liquidnet Holdings.

Notable practitioners  

Alan Avery is highly regarded for his "experience and expertise" in a wide range of regulatory matters impacting financial institutions. His "very good technical knowledge" ensures that he is a popular choice among big-name clients.

Dana Fleischman maintains her "well-deserved credibility and great reputation" in the broker-dealer compliance space, and is widely regarded as a leading figure whose "years of experience and breadth of knowledge" see her handle an impressive spread of regulatory matters for clients. Clients are quick to praise the "practical advice" she provides and her "very responsive" approach.

Stephen Wink offers notable expertise across a range of regulatory matters impacting broker-dealers and other entities in the financial services arena. He recently advised Deloitte on the addition of a broker-dealer to its financial services offering.

Significant clients Morgan Stanley, Rabobank, National Bank of Canada, Jefferies, Bank of America Merrill Lynch.

Basic facts about the department
Key offices include New York and Washington, DC.

What the team is known for Attracts a sophisticated global client base drawn to its impressive cross-border capabilities in the financial services regulatory arena. Regularly handles complex compliance matters for a range of financial institutions, while also offering significant strength on the investigation and enforcement side.

Strengths (Quotes mainly from clients)
"They are fantastic: they keep you informed, are very practical in terms of their advice and are efficient."

"Their timely and proactive approach is very valuable to us." 

Notable practitioners  

Scott Anenberg is a notable banking regulatory compliance attorney, whose longstanding experience in representing a range of financial institutions sees him well placed to tackle a wide range of issues. His global perspective is of particular note to clients, with one stating: "He stands out for his international focus."

Marc Cohen enters the rankings having returned from a secondment at the firm's London office. He handles a range of regulatory compliance matters for banking institutions, and is lauded as a "practical problem solver" by clients. One source noted: "He sees the problem from all angles, and brings to bear appropriate solutions from a variety of disciplines."

Thomas Delaney's practice spans a range of banking enforcement matters, but he is particularly noted for his focus on Dodd-Frank compliance. He is noted by clients for the deep expertise that he brings to his practice, and is characterized as a "thoughtful and practical" attorney.

Jerome Roche is "very knowledgeable about pretty much all aspects of broker-dealer regulations," according to sources. His "ability to cut right to the heart of an issue" is particularly regarded by commentators, as is his cross-border expertise.

Significant clients UBS, Capital One, State Bank of India, CIBC, The Northern Trust Company.

Basic facts about the department
Key offices include Albany and New Orleans.

What the team is known for Houses impressive strength across the increasingly complex regulatory arena, regularly acting for a range of financial institutions on compliance matters and litigation related to the consumer finance market. Often noted for its depth of expertise in matters related to the mortgage industry, and is praised by clients for its strategic strength and practical approach.

Strengths (Quotes mainly from clients)
"Very strong knowledge of consumer finance and real estate."

"Strong, quality firm which has served us well; I know where to go on matters involving consumer finance."

Work highlights Acted for new residential and commercial mortgage lender First Key Holdings on matters related to its nationwide lending licensing.

Advised American Residential Communities on a number of matters related to its manufactured home business across multiple states. 

Notable practitioners  

Bennet Koren is acclaimed as a leading expert in consumer finance compliance, and is praised for his longstanding experience in this space. He represents a range of financial institutions across a range of regulatory issues, and is highlighted as being "extremely knowledgeable" while "providing practical advice."

Marc Lifset is repeatedly endorsed as an expert in the manufactured housing space, and is regarded by clients as a go-to attorney in this space thanks to the depth of his expertise in regulatory matters surrounding lending. He recently acted for the Manufactured Housing Institute in relation to matters such as compliance with the Dodd-Frank Act and anti-money laundering regulations.

Significant clients Mercedes-Benz Financial, Westlake Financial Services, Santander, Bank of America, Prospect Mortgage.

Basic facts about the department
Key offices include New York and Washington, DC.

What the team is known for Focuses on broker-dealer compliance and enforcement work on behalf of major financial institutions and securities firms, with expertise in enforcement defense, investigations and litigation. Regularly handles sophisticated proceedings involving multiple broker-dealers as compliance counsel.

Strengths (Quotes mainly from clients)
“Overall, I think they are excellent. They give practical, rule-based guidance.”

Work highlights Represented more than 40 broker-dealers in a series of compliance issues, including sales and trading advice, municipal bond sales, online public offerings and internal reorganizations.

Acted for Morgan Stanley in relation to investment in New York brokerage firm Auerback Grayson & Company, subsequently making it a Morgan Stanley executing broker in emerging markets.

Notable practitioners  

Charles Horn recently joined the firm from Morrison & Foerster. He handles banking compliance work on behalf of financial institutions and is experienced practicing before significant state and federal financial regulatory agencies.

Investment management practice head Steven Stone focuses his practice on broker-dealer enforcement and regulation. He was recently involved in the representation of more than 20 broker-dealers in a series of SEC and FINRA proceedings.

John Ayanian is held in high regard by broker-dealer clients for his work on compliance issues and related transactions. Sources say he “communicates in an uncomplicated manner, is readily available and responsive, and is results-driven and action-oriented.”

David Boch is praised by commentators for his practical approach to complex broker-dealer enforcement issues. Clients benefit from his experience in SEC and FINRA regulatory proceedings. Boch recently joined the firm from Bingham McCutchen.

Significant clients Barclays Capital, Credit Suisse, Deutsche Bank, Goldman Sachs, JPMorgan Securities.

Basic facts about the department
Key offices include New York, Los Angeles, San Francisco and Washington, DC. 

What the team is known for Maintains a superb reputation for regulatory matters pertaining to consumer finance, most impressively with respect to the credit card space, but with increasing presence in the mortgage arena. Offers highly respected compliance and litigation support via an impressively deep bench of talent, with attorneys routinely acting on matters at the forefront of developments from the CFPB. Also noted for its strength with respect to the wider banking compliance sphere, with the firm's global footprint making it a strong choice for foreign banks operating in the USA.

Strengths (Quotes mainly from clients)
"It's very helpful to have a firm like it that has our interests at heart as well as I do. They understand what the end game is for the business even before we do."

"Morrison & Foerster has excellent client service. They are always available for our concerns."

What's new? Donald Lampe, a respected consumer finance attorney with expertise in the mortgage sphere, has joined the firm from Dykema Gossett.

Work highlights Acted for TD Bank with respect to obtaining regulatory approval for its acquisition of the credit card portfolio of Target National Bank.

Advised H&R Block on the sale of its bank assets to Republic Bancorp.

Notable practitioners  

The "outstanding" Richard Fischer is universally lauded as a market leader in the consumer finance realm, advising banks and technology companies on the regulatory requirements surrounding payment systems, data security and consumer lending. "I don't think it's an exaggeration to say he's known as a legend in this field," remarks one peer.

Henry Fields is recognized for his handling of banking compliance and M&A matters. He recently advised Western Liberty Bancorp on its sale to Western Alliance Bancorporation.

DC-based Oliver Ireland advises banking and consumer finance clients on regulatory matters. He is particularly highly rated by market observers for his understanding of CFPB and Federal Reserve regulations. Recent matters include advising JPMorgan Chase, among other leading financial institutions, on the implementation of reforms required by Dodd-Frank and the Consumer Protection Act.

Barbara Mendelson is "very good at being proactive and telling us what we should know about," relates one impressed client. Mendelson has recently been active advising foreign banks on the preparation of 'living wills' under Section 165 of Dodd-Frank.

The "very user-friendly and attentive" Mark Ladner is a consumer finance litigator who has represented many of the leading retail banks and credit card lenders in consumer class actions concerning matters such as credit card fees and collateral protection insurance programs.

Donald Lampe offers a broad consumer finance practice with a particular focus on advising mortgage companies in connection with regulatory compliance strategies. Sources affirm that he is "one of the best" in this space.

San Francisco-based James McGuire enters the rankings for the first time after receiving strong feedback for his consumer finance litigation expertise, notably with respect to the defense of consumer class actions. Recent clients include US Bank and Capital One.

Thomas Noto handles regulatory and enforcement matters affecting mortgage lenders and servicers. He has recently represented a number of financial services clients with respect to Office of the Comptroller of the Currency (OCC) and CFPB investigations regarding products offered by third-party vendors.

Consumer finance compliance attorney Leonard Chanin is "a careful and conscientious lawyer" and "truly an expert in his subject matter," say sources. His areas of expertise include the Truth in Lending Act, the Equal Credit Opportunity Act and the Fair Credit Reporting Act.

Michael Agoglia is a consumer finance litigator whose broad practice has included representing financial institutions in defense of challenges to a range of issues including alleged unfair business practices and privacy breaches.

Significant clients Capital One, Citibank, JPMorgan Chase, TD Bank, Wells Fargo.

Basic facts about the department
Key office is Washington, DC.

What the team is known for Offers particular strength in assisting domestic and foreign banks on complex banking transactions as well as advising financial services firms across a broad range of transactional, compliance and bank regulatory matters, not least on issues pertaining to the implementation of the Dodd-Frank Act. Also renowned for its payment regulation work, providing counsel on issues including global money transfer programs, mobile banking ventures and data privacy. 

Strengths (Quotes mainly from clients)
"Efficient – overall an exceptional group."

Work highlights Continued to work extensively with a range of Charles Schwab companies, including Charles Schwab Corporation and Charles Schwab Bank, on a variety of matters, from providing advice on structural and operational issues to addressing Dodd-Frank compliance and developments.

Assisted JPMorgan Chase with its payroll card program and related product offerings with regard to issues concerning the Federal Reserve Board’s interchange rule Regulation II, required by the Dodd-Frank Act. 

Notable practitioners  

Global banking practice chair Gerard Comizio is noted for his work concerning regulatory and enforcement proceedings and regulatory and strategic planning issues, acting for a client base that includes both leading US and international banks, mortgage companies, specialty lenders and private equity companies. He is additionally highlighted for his expertise on GSE reform and residential loan securitization issues.

Significant clients Citibank, eBay, Facebook, Visa, PayPal.

Basic facts about the department
Key office is New York.

What the team is known for Provides remarkable litigation expertise and a broad bench of strong general enforcement lawyers, admired for their intuitive approach and ability to handle difficult issues. Represents major financial institutions and is a go-to group for hedge funds. Has constantly evolving awareness of the investigative, litigation and regulatory challenges affecting financial services clients.

Strengths (Quotes mainly from clients)
"An outstanding performance overall. They are very responsive and very open in communicating so I'm always pretty current on what they're thinking."

"They're so good that we keep going back." 

Work highlights Continues to advise Citigroup Global Markets in an industrywide investigation by the SEC into the way in which CDO securities are structured, marketed and sold.

Retained at short notice by Bank of America to appear on behalf of the bank in a securities class action lawsuit in which $25 billion was at stake.

Notable practitioners  

Firm chair Brad Karp is considered to be an invaluable resource by his clients, with one affirming that he is "a superb all-round lawyer with great judgment. I always want him on my side no matter what the issue." Karp is also described by sources as "one of the best litigators in the country" and his substantial expertise includes counseling major banking clients in SEC investigations and enforcement matters.

Significant clients The Bank of New York Mellon, Deutsche Bank, Standard Chartered, HSBC, JPMorgan Chase.

Basic facts about the department
Key offices include New York and Washington, DC.

What the team is known for Longstanding practice maintaining a fine reputation for banking regulation compliance work, serving a broad client base ranging from banks, broker-dealers and exchanges to clearing and settlement providers and fund groups. Well versed in structuring and facilitating businesses through acquisitions and financial reorganizations, and additionally routinely sought after to handle the regulatory aspects of capital markets offerings and investment fund formations. Also increasingly recognized for its expertise in broker-dealer compliance and enforcement.

Strengths (Quotes mainly from clients)
"Service levels are exceptional. Regarding the quality of advice, we benefit from a well-balanced mix of pure legal analysis and practical business application of legal principles."

"They provide excellent advice, are very responsive to clients, and have experts in their respective fields."

Work highlights Acted for China Construction Bank on the formation and registration of a US-based investment banking and securities trading operation, which involved overseeing arrangements with affiliated non-US broker-dealers and distribution of research produced by non-US affiliates, as well as handling related membership with FINRA.

Assisting Itaú Unibanco with obtaining US approvals for the transfer of a Portuguese bank to the United Kingdom. The matter involves the regulatory impact on US subsidiaries.

Notable practitioners  

Practice group co-leader Bradley Sabel is of counsel at the firm and is recognized for his US banking regulation expertise on behalf of a range of international financial institutions. "He always provides very useful advice," reports one impressed client.

Don Lamson is well equipped to handle a wide variety of bank regulatory and supervisory matters, from M&A, derivative activities and capital markets issues to internal investigations, enforcement and consumer compliance. Commentators reserve particular praise for his hard-working approach to matters.

Sources single out Russell Sacks as being "very knowledgeable, user-friendly and practical in his advice." He comes recommended for his strengths in trading and markets issues, in addition to regulatory and transactional matters.

Tim Byrne is increasingly coming to the attention of market observers for the strength of his burgeoning banking compliance practice. Sources note his "excellent subject matter expertise" and remark that he is "just a pleasure to work with." Byrne recently joined the team from Cleary Gottlieb Steen & Hamilton LLP.

Significant clients Natixis, Mizuho Corporate Bank, Barclays, Reliance Financial, Citi Private Bank, Bank of America.

Basic facts about the department
Key offices include New York, San Francisco and Washington, DC.

What the team is known for A heavyweight player in the financial services regulatory sphere, most notably with respect to the broker-dealer space, where a formidably strong bench covers the most cutting-edge compliance and enforcement matters for some of the most recognizable securities trading institutions in the world. Solid reputation in both the banking and consumer finance regulatory compliance matters, advising US and foreign financial institutions in connection with all aspects of Dodd-Frank, including those relating to the Volcker Rule and the CFPB.

Strengths (Quotes mainly from clients)
"I think they are an absolutely outstanding firm. I have never had any issues at all in terms of quality or timeliness. They are first-class and extremely talented."

"The leading practitioners in the regulatory investigation space for broker-dealers."

"They have good, sound judgment, they understand the business and they understand the regulatory environment."

Work highlights Represented a number of broker-dealer clients with respect to FINRA investigations relating to aggregation units and Regulation SHO.

Advised UBS in connection with a number of matters including the implication of changes in the Dodd-Frank Act that limited exemption from the Truth in Lending Act.

Represented Green Dot in connection with regulatory issues arising from its prepaid card business and retail banking operations.

Notable practitioners  

Hardy Callcott is a leading figure in the broker-dealer sphere, representing clients in both regulatory compliance and enforcement matters. Sources say he is "very astute, practical and an excellent communicator," and note that he has "an outstanding knowledge of the regulators."

William Eckland is a well-regarded practitioner in the banking regulatory space. Sources commend his "breadth of knowledge and practical advice." Eckland's clients include Wintrust Financial, Discovery Financial Services and Morgan Stanley.

Connie Friesen advises domestic and foreign financial institutions on US regulatory compliance. She recently advised Axis Bank, an Indian financial institution, on the implications of US state money transmitter licensing requirements.

Susan Merrill is particularly recognized by market observers for her representation of broker-dealer clients in enforcement actions before FINRA and the SEC. Sources affirm that she is "very tenacious and very knowledgeable about securities enforcement."

Neal Sullivan enjoys a fine reputation in broker-dealer enforcement matters. In the words of one market observer, he "has tremendous relationships with key regulators and provides outstanding legal advice."

James Brigagliano is a respected former SEC official who is continuing to impress since his move into private practice in 2012. He is noted for his counseling of broker-dealer clients on a wide range of matters, including of late short selling, Rule 105 and order handling.

SEC alumnus Kevin Campion heads the broker-dealer securities regulatory practice group. He focuses his practice on providing a full range of regulatory compliance advice to broker-dealer clients.

Dennis Hensley "has tremendous experience and provides excellent advice" in connection with broker-dealer regulatory rulemaking by the SEC and FINRA, according to one impressed client.

The "very well-respected" James Huizinga offers a broad consumer finance practice, encompassing regulatory compliance advice and litigation.

David Teitelbaum is described by one interviewee as "super smart, always thoughtful and very efficient." Teitelbaum is recognized for his provision of ongoing operational regulatory compliance advice pertaining to consumer finance matters.  

Significant clients Bank of America, Barclays, Jefferies, Morgan Stanley, RBS.

Basic facts about the department
Key office is New York.

What the team is known for Regularly acts for major financial institutions including banks, mortgage brokers and, particularly of late, credit card issuers in significant M&A deals as part of the firm's market-leading corporate transactional expertise. Also offers clients a strong presence in sophisticated banking regulation and compliance issues in relation to key legislative developments including Dodd-Frank and Basel III.

Strengths (Quotes mainly from clients)
“They have a good practice, and are willing to give clear advice and tell you what their view is.”

Work highlights Represented TD Bank in its high-value acquisitions of Target's US credit card portfolio and Epoch Holding, with a combined value of more than $6 billion.

Acted for Best Buy in relation to Citi's acquisition of the retailer's $7 billion credit card portfolio from Capital One.

Notable practitioners  

The "very talented" Lee Meyerson acts for financial institutions in complex M&A and capital markets transactions. Recent highlights include representing TD Bank in the $668 million acquisition of Epoch Holding.

Maripat Alpuche is lauded as a "quite good and quite commercial" practitioner in financial institution M&A transactions. She recently led the firm's representation of Best Buy following Capital One's sale of its credit card portfolio to Citi for $7 billion.

Elizabeth Cooper focuses her practice on M&A transactions involving major financial institutions. She recently acted for Mitsubishi UFJ Trust & Banking on its acquisition of investment fund administrator Butterfield Fulcrum Group.

Significant clients AIG, The Carlyle Group, First Hawaiian Bank, Goldman Sachs, JPMorgan Chase.

Basic facts about the department
Key offices include New York and Washington, DC.

What the team is known for M&A powerhouse with an impressive breadth of practice in the financial services arena. Regularly advises banks and other financial institutions in relation to transactions and related due diligence. Also on hand to provide day-to-day advice on regulatory compliance and assistance with more irregular and complex matters, such as enforcement concerns, major litigation and internal and government investigations. 

Strengths (Quotes mainly from clients)
"We're thrilled with their work. We've used them globally across borders on regulation and regulatory matters. They work seamlessly. Great value for service."

"Overall you get what you pay for. They're not cheap but their services have been outstanding."

"Impressed with the consistent quality of everyone associated with the firm. They have the intellectual and interpersonal skills." 

What's new? The firm recently welcomed OFAC's former chief counsel Sean Thornton to its financial institutions regulation and enforcement group. In his seven years as chief counsel, Thornton was central to a series of historic settlements with international banks regarding alleged violations of US sanctions. 

Work highlights Represented Wells Fargo in relation to conciliation agreements with HUD, Jacksonville Legal Aid and the National Fair Housing Alliance and 13 of its member groups. The agreements relate to complaints against mortgage servicers that they did not maintain the condition of foreclosed REO (real estate owned) properties in minority areas, and that they had maintained properties in nonminority areas, violating federal antidiscrimination laws. The agreements achieved a global resolution for Wells Fargo and set a precedent for the industry.

Acted as regulatory compliance counsel to International Bancshares Corporation (IBC), advising on, among other things, the Community Reinvestment Act, fair lending and unfair and deceptive acts or practices. Also advising IBC in connection with pending federal legislation relating to bank regulatory reform.

Represented AmericanWest Bank in its purchase of PremierWest Bank. Also represented AmericanWest Bank in relation to its as yet uncompleted purchase of eight branches from Pacific Trust Bank.

Notable practitioners  

The "absolutely outstanding" William Sweet is hailed for his "unfailingly practical and helpful advice" to financial institutions, which includes acting as counsel on M&A and regulatory and enforcement matters. "He is a terrific lawyer all around and a good person," said one source, while another acknowledged that "he is the one who I think merits some real kudos."

Jamie Boucher counsels a wide variety of financial institutions on regulatory and enforcement matters and M&A. She is well versed in representing international banks in complex multijurisdictional compliance and enforcement matters.

Financial institutions go to Joseph Barloon for assistance in criminal and civil litigation and both government and internal investigations. He also provides compliance advice and due diligence in relation to transactions. "His recommendations to us I always find to be very balanced," said a source; "he understands the legal perspective but also the business perspective."

Sources say Anand Raman "is very seasoned and has a real breadth of experience dealing with financial services matters and with regulators at a very high level." He handles agency enforcement matters, class action litigation and internal investigations.

Sven Mickisch earns praise for being "extremely user-friendly, highly intelligent and a problem solver," and for being someone who "really tries to understand the bank's position before the engagement." He advises financial institutions in relation to a wide range of corporate transactions.

Associate Austin Brown is "technically very sound and really knows his stuff," according to sources, who also make note of his "good judgment, well-considered opinions and ability to distill advice into practical utility." He focuses on regulatory compliance and enforcement.

Significant clients Sumitomo Mitsui Banking, MetLife, Stone Point Capital, First California Financial Group.

Basic facts about the department
Key office is New York.

What the team is known for A truly elite financial institutions team, with a prestigious assembly of talent that has been on the front line of every major regulatory development in the industry over recent years. Routinely called upon by many of the most systemically important financial institutions operating in the USA to advise on the most complex rulemaking to emanate from the Dodd-Frank Act and the regulatory bodies. Outstanding track record in terms of defending banks in relation to investigations and enforcement actions by the SEC, FINRA and other agencies. Equally impressive transactional abilities in the financial services space, helping banks and other financial institutions navigate the regulatory minefield surrounding M&A deals.

Strengths (Quotes mainly from clients)
"Sullivan & Cromwell obviously continues to be the gold standard in this space."

"They're very responsive, and their reputation and industry knowledge are also very impressive."

"Their advice and counsel is majorly important to us. They are excellent - the strongest financial services law firm."

Work highlights Represented American Express and Goldman Sachs in regulatory matters arising from their conversions to bank holding companies.

Continued to act as national coordinating counsel for JPMorgan Chase in relation to litigation and regulatory matters stemming from its sale of RMBS prior to the financial crisis.

Advised Bancolombia in connection with its $2.1 billion acquisition of HSBC Panama.

Notable practitioners  

Rodgin Cohen is a preeminent figure in the financial services industry and continues to be recognized by peers and clients alike as "a legend in the field." His excellence spans the full range of regulatory issues experienced by banking clients, including compliance, enforcement and M&A matters. Cohen is "a true gentleman and a practitioner of the highest caliber. The man is just incredible," says one interviewee, while another suggests that "he walks on water."

Michael Wiseman is widely considered to be a market-leading attorney for handling regulatory compliance, enforcement and M&A matters for financial institution clients. Recent matters include advising American Express and Goldman Sachs in connection with their conversions to bank holding companies. Wiseman is co-head of the financial institutions group.

The "outstanding" Mitchell Eitel is co-head of the firm's financial institutions team. He is recognized for his handling of compliance and M&A matters, recently acting for Bankia in connection with its sale of City National Bank of Florida to BCI. Sources attest to his "truly consistently good work."

Michael Escue is a "very fine lawyer" who maintains a prominent banking compliance practice. He recently advised various foreign banks, including China Merchants Bank and the Bank of Ireland, on the establishment of operations in the USA.

Donald Toumey is a highly regarded banking compliance specialist who has recently advised a number of domestic and foreign clients with respect to a range of matters, including affiliate transaction rules under Sections 23A and 23B of the Federal Reserve Act.

Mark Menting is an "outstanding" regulatory attorney whose practice includes banking compliance and M&A work in the financial services space. He recently advised EverBank Financial on its acquisition of Business Property Lending.

Washington, DC-based William Kroener is particularly noted by market observers for his knowledge of FDIC regulatory matters, having previously acted as general counsel to the agency.

Whitney Chatterjee continues to be recognized as a rising star for banking compliance matters. She recently advised CIT and GE in connection with a range of regulatory matters.

Karen Patton Seymour comes highly recommended for her representation of financial institutions in investigations and enforcement matters by regulatory agencies, and in criminal trials brought by the DOJ. Recent highlights include representing Goldman Sachs in a series of regulatory actions and litigations stemming from its sale of MBS.

Samuel Seymour is a regulatory enforcement specialist and white-collar criminal litigator who recently represented Standard Chartered Bank in deferred prosecution agreements with the DOJ and in regulatory agreements with the New York State Department of Financial Services, the Federal Reserve and OFAC. The matter concerned anti-money laundering compliance and OFAC sanctions.

Significant clients American Express, Goldman Sachs, Barclays, Bank of Montreal, JPMorgan Chase.

Basic facts about the department
Key office is Washington, DC.

What the team is known for Maintains an impressively broad-based financial services practice, regularly advising a wide range of institutions on an array of regulatory compliance and enforcement matters. Houses an expert group of practitioners whose prior experience at organizations such as the CFTC, the DOJ and the Office of Thrift Supervision is a key selling point for clients. Demonstrates additional versatility in its adept representation of both financial organizations and individuals in investigations conducted by bodies such as the FDIC.

Strengths (Quotes mainly from clients)
"Venable is an outstanding, value-based firm, and its lawyers are very knowledgeable about their particular areas."

"They are all extraordinarily experienced and very thoughtful. You get a very thoughtfully crafted, bespoke product."

Work highlights Advised diverse industry groups such as the Texas Bankers Association - Lawyers Committee on a range of matters related to the implementation of the Dodd-Frank Act.

Acted for several former directors and officers of the North Carolina Cooperative Bank in relation to a $33 million complaint made by the FDIC.

Notable practitioners  

Ronald Glancz chairs the firm's financial services group, and is held out by commentators as a leading expert in enforcement and investigatory matters related to the banking industry. This expertise is coupled with a highly praised client-centric approach, with his "focus on problem solving" and approachable manner ensuring ongoing popularity in the market.

John Beaty is hailed as both a "legal counselor, and a very thoughtful business adviser," and is noted for his "extremely knowledgeable" and "very pragmatic" manner. He draws on notable experience in the banking compliance space when working with a range of key clients.

Clients are quick to praise banking compliance and enforcement expert Ralph Sharpe for his "really exceptional" understanding of the regulatory landscape in the financial institutions arena. He is particularly acclaimed for his ability to bring together legal understanding and business sense, with one source stating: "If you need a solution that's really going to work from a practical standpoint and be thought through, Ralph is your guy."

Significant clients MidFirst Bank, Auto Club Trust, USAA Federal Savings Bank, TCF Financial, ZenBanx.

Basic facts about the department
Key office is New York.

What the team is known for Continues to be recognized for its cutting-edge work relating to M&A in the financial services industry, with a long track record of advising on the most prominent and complex domestic and cross-border deals in the sector. Additionally respected for its banking compliance work for a range of financial institutions.

Notable practitioners 

Edward Herlihy is considered by many market observers to be an "absolute star" of the financial institutions M&A space. Areas of excellence include a full range of transactional matters, including recapitalizations and M&A.

Richard Kim is a respected figure in the regulatory sphere, advising banks in connection with M&A and ongoing operational issues. Sources describe him as "a very fine lawyer."

Patricia Robinson continues to impress commentators with her banking compliance practice. Sources applaud her "talented and thoughtful" counsel.

Nicholas Demmo handles M&A work in the financial services space, and is noted for his handling of some of the most complex deals in this space.

Significant clients Bank of America, Wells Fargo, Morgan Stanley, Capital One, Santander.

Basic facts about the department
Key office is New York.

What the team is known for Accomplished banking practice, noted for its utilization of the firm's excellent worldwide platform to advise domestic banking clients on cross-border regulatory matters as well as non-US institutions on issues relating to their US operations. Sought after to handle all manner of regulatory compliance issues, and represents a fine choice of counsel for Dodd-Frank matters, internal investigations and governmental enforcement proceedings, and issues regarding the impact of restrictions on geographical expansion.

Strengths (Quotes mainly from clients)
"The people we work with are very responsive and have done a very good job."

"They've been very accommodating to us under difficult circumstances."

Notable practitioners  

Ernest Patrikis comes recommended for his wealth of experience accrued during the three decades he spent working at the Federal Reserve Bank of New York and is highly regarded for his work on behalf of cross-border banking clients on US regulatory issues.

Basic facts about the department
Key offices include New York and Washington, DC.

What the team is known for Represents the world's leading financial institutions on critical compliance issues. Maintains a sterling reputation for broker-dealer work, with additional expertise in banking and consumer finance compliance. Offrs complementary strength in securities regulation and litigation, and includes several SEC alumni within the ranks, making the team especially appealing to high-level clients with complex enforcement and counseling needs.

Strengths (Quotes mainly from clients)
"They are the smartest, best people out there on financial services regulation matters, particularly broker-dealer stuff. I find them to be very smart, very knowledgeable and very client service-oriented. A pleasure to deal with; very responsive."

"A great firm, and that quality is very consistent throughout." 

Work highlights Advised members of SIFMA's executive committee and regulatory board on drafting a white paper addressing securities regulatory changes since the financial crisis.

Worked with HSBC on a comprehensive, multinational internal investigation process running contemporaneously with civil and criminal proceedings brought by the DOJ and IRS. The investigation involved international banking operation and tax issues.

Notable practitioners  

Yoon-Young Lee is singled out as being "terrific" by several sources, who emphasize that "sophisticated clients rely on her." Lee chairs the broker-dealer practice, and spearheaded the firm's recent white paper work for SIFMA.

Bruce Newman is another of the firm's highly regarded broker-dealer partners and is praised by one client as being "uniquely strong in the fixed-income markets." Newman's experience and levelheadedness are key strengths: "He is a great steady hand when in a difficult situation."

Sources note that Andre Owens has developed impressively "wide and broad experience; his years at the SEC served him really well in that regard." His expertise in trading issues distinguishes him in the broker-dealer arena.

Clients say Franca Harris Gutierrez is "very well versed in regulatory affairs for financial services institutions." She has a broad skill set and has advised some of the biggest names in the industry on their compliance and enforcement needs.

Russell Bruemmer's recent work highlights include leading for HSBC in an extensive internal investigation. He is well known for his adept handling of sensitive matters for multinational clients and is noted for his "remarkable commercial sense."

Rising star Stephanie Nicolas is known for her tremendous client service skills and deep understanding of regulatory issues confronting broker-dealer clients.

Significant clients Credit Suisse, JPMorgan Chase, UBS, Goldman Sachs, Jefferies.

Basic facts about the department
Key offices include Chicago, New York and Washington, DC.

What the team is known for Acts for banks, broker-dealers, hedge and private equity funds, and governmental entities, among others, on a wide variety of regulatory and transactional matters. Strong regulatory compliance practice, which includes representation of both domestic and non-US clients before federal and state agencies, as well as before arbitration panels and international tribunals. Also well equipped to provide related advice concerning corporate governance, tax issues and dispute resolution.

Strengths (Quotes mainly from clients)
"The work required highly qualified and sophisticated representation, which is what the team delivered."

"They're responsive, have a deep bench and produce high-quality output."

Work highlights Acted for the Financial Services Roundtable, the DC-based trade association of the top 100 financial services companies, on matters including SEC rules, executive compensation changes and new international capital standards.

Notable practitioners  

The "very talented" Julius Loeser is of counsel at the firm. He is noted for his wealth of experience in a wide range of banking regulation matters and is much sought after for his strengths in issues pertaining to OCC and FDIC regulations, financial modernization and lending limits.

Department head Christine Edwards comes recommended for her corporate governance work, in addition to her securities and banking regulatory expertise. Commentators single out her practical advice, organizational skills and efficient approach to matters, and also praise her "delivery of razor-sharp analysis and keen business insight."

Significant clients Continental Investors, Comerica Bank, Bank of Hawaii, JPMorgan Chase, TCF National Bank.

Basic facts about the department
Key office is Washington, DC.

What the team is known for Fine, compact team with an established reputation for its work concerning MBS. Substantial experience handling securities violations, accounting and tax fraud, and insider trading issues, and well versed in representing institutions and individuals before federal agencies, including SEC, FDIC and CTFC.

Strengths (Quotes mainly from clients)
"They put together a very talented team of people with different specialties and approaches to the problem. I was impressed with the breadth and depth."

"Terrific - an outstanding law firm, extremely deep bench."

Work highlights Recently obtained summary judgment on behalf of Timothy Howard, former CFO of Fannie Mae, following eight years of litigation, concerning claims filed by investors in relation to alleged securities fraud.

Continued to act for Freddie Mac's former chief business officer, Patricia Cook, in litigation brought by the SEC, as well as in a parallel class action that is pending in the Northern District Court of Ohio, regarding several alleged counts of securities fraud.

Notable practitioners  

"Great lawyer" Steven Salky heads the financial services group and is recognized for his strengths in securities fraud investigations and related class action cases. He wins particular praise for his breadth of knowledge and efficient approach to matters.

Significant clients Goldman Sachs.

Foreign Experts

Foreign Experts are individuals with expertise in a different jurisdiction to the one they are based in. These individuals are particularly highly regarded for international and cross-border work. Usually, they will be identified in the jurisdiction in which they are based and in their country of expertise.

Senior Statesman

A 'Senior Statesman' is a lawyer who no longer works hands-on with the same intensity but who, by virtue of close links with major clients, remains pivotal to the firm’s success.

Eminent Practitioners

'Eminent Practitioners' are highly influential lawyers in a particular practice area who, due to managerial or client relationship commitments, are less active in day-to-day work but remain key players in the team.

Other Noted Practitioners

Other Noted Practitioners are individuals who have not yet been ranked but are seen to be active and accomplished in this area of law.

Other Noted Firms

Other Noted Firms are firms that have not yet been ranked but are seen to be active and accomplished in this area of law.