Bank Regulatory

DWT assists banks and financial services firms in navigating a complex, ever-evolving regulatory landscape. We advise our clients on managing their regulatory, compliance, and supervisory risks by finding the right solutions for their business needs.

Overview

Our bank regulatory team—recognized as nationwide financial services regulation leaders by Chambers USA and Legal 500—has deep industry knowledge and includes attorneys with extensive government and regulatory experience at the Federal Reserve Board, The Federal Deposit Insurance Corporation, U.S. Treasury Department's former Office of Thrift Supervision, Consumer Financial Protection Bureau, Department of Justice, Massachusetts Attorney General's office, and former U.S. House Banking Committee. Additionally, several of our attorneys have served as in-house counsel at global financial institutions.

We represent clients before various state regulators, including the New York Department of Financial Services and the Division of Financial Institutions of the California Department of Business Oversight. Beyond working with these and other relevant agencies, DWT advises clients on key legislative issues pending on Capitol Hill.

Our attorneys counsel large and small banks and financial services firms on both retail and commercial banking activities and resolution planning. We also advise foreign banking organizations, broker-dealers, payment and fintech firms, private equity firms, hedge funds, and third party service providers to banks and financial institutions on a wide range of compliance, regulatory, supervisory, and transactional issues.

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Bank Regulatory

BSA/AML material risk review
Represented large non-U.S. bank in connection with material risk review of U.S. Operations and substantial account activity sourced in various Latin American countries.

Enhanced prudential standards
Representation of several large U.S. bank resolution plans and issues regarding Dodd-Frank Act enhanced prudential standards, including advising a large U.S. bank in transitioning through advanced approaches requirements.

Basel III capital rules
Represented several regional and community banks on implementation of the Basel III capital rules and worked with clients to issue comments on the interagency proposal for implementation of such rules.

Restructuring under Dodd-Frank
Representing domestic and foreign banks, foreign funds, and private equity firms on provisions and applicability of the Volcker Rule and related issues under the Dodd-Frank Act.

Anti-Tying and affiliates with transaction issues
Representing several financial conglomerates on Federal Reserve Board anti-tying laws and requirements and affiliate transaction restrictions, with specialized expertise in the area of broker-dealer and bank cross-product services.

Bank sweep programs and brokered deposits
Representing U.S. bank entities with affiliate broker dealer to develop sweep fund tower programs and provide guidance on regulatory issues regarding brokered deposits.

International and Cross-Border

OFAC sanctions risks
Represented large international industrial conglomerate on potential OFAC sanctions risks arising from proposed acquisition.

Cross-border Dodd-Frank matters
Represented foreign subsidiary of a large U.S. bank holding company on CFTC’s cross-border application of Dodd-Frank swaps.

Compliance for international firms
Represented large international financial firm on application of U.S. Bank Secrecy / Anti-Money Laundering laws and compliance with requirements of the Office of Foreign Assets Control

Consumer Finance Regulatory

CFPB matters
Representation of various nationwide payments networks and financial services firms on rules and guidance issued by the CFPB, including the agency’s international remittance rule

Counseling on emergency loan program
Represented large international insurance firm on federal and state issues related to implementation of an emergency loan program for is employees.

U.S. surveys on various consumer issues
Representing FinTech firms in providing 50-state regulatory analysis and review on state laws in multiple areas, including credit card surcharge laws, money transmitter licensing laws, lending laws, and data breach and privacy laws.

Operations and Risk Management Tab

Regulatory change management
Representing large U.S. bank holding company in developing a regulatory change management program to identify regulatory developments impacting bank and holding company policies.

Advise on regulatory examination
Represented large firms in approaching examinations with regulatory agencies, streamlining business line interactions, and providing insight to yield focused interactions.

Counsel on direction and impact of agency guidance in risk management
Representing large U.S. banking holding company in understanding impact of risk management on Federal Reserve Board financial ratings, and guiding bank board in comprehending regulatory expectations.

Third-party risk management
Representing large banks in understanding and navigating third-party risk management measures in vendor contracts.