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Desktop Image: Max Bonici
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Max Bonici

Partner

T 202.661.7034 Washington, D.C.
T 212.402.4026 New York
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Max Bonici advises domestic and international financial institutions on regulatory, supervisory, and enforcement issues. He also represents fintechs and nonbank tech companies and supports the firm's M&A work in the middle-market financial services space, drawing on 15+ years in private legal practice and government experience—including at the FDIC and the IMF—to help clients navigate complex and evolving laws, expectations, and enforcement priorities.

Financial services providers look to Max for advice on chartering, powers and structure issues, and compliance with regulations and standards set by the Federal Reserve, FDIC, OCC, CFPB, FinCEN, OFAC, and state banking regulators. He counsels on permissible activities, controlling and noncontrolling equity investments, third-party relationships, prudential requirements, the Dodd-Frank Act and the Volcker Rule, digital assets, and deposit insurance issues, including applications and coverage, brokered deposits, and passthrough insurance. He helps financial institutions and fintechs partner to establish financial services solutions, platforms, and products and services. He also helps non-U.S. banks and fintechs enter the U.S. market.

On the supervisory front, Max has extensive experience handling civil and internal investigations, as well as appeals of supervisory ratings and findings. When disputes arise, Max also advises litigation teams on important regulatory and supervisory expectations.

Recognized by The Legal 500 in financial services regulation, Max regularly writes and presents on traditional and novel banking and fintech issues. He serves on the board of directors of Women in Housing and Finance, a nonprofit and charitable foundation that supports diverse professionals in the financial services and housing sectors, and as co-chair of the Enforcement Subcommittee of the American Bar Association's Banking Law Committee.

Practice Highlights

Regulatory

Advised financial services providers and those who work with them in navigating a complex and changing regulatory framework to grow, innovate, or offer new products and services. Particular focus on Federal Reserve, FDIC, and OCC regulations.

Supervision

Helped banks and their service providers prepare for, respond to, and remediate examination issues and expectations, including in multi-agency exams.

Enforcement

Advised financial institutions and others in federal and cross-border investigations and remediation efforts. Responded to civil investigative demands and navigated voluntary self-disclosure processes and related internal investigations.

Applications*

Advised on and managed regulatory applications and other filings for financial institutions, bank holding companies, and affiliates, including bank merger and bank holding company merger filings. Also advised on Federal Reserve and OCC filings to engage in new activities at the bank or holding company levels.

Foreign banking*

Advised on the establishment of U.S. branch and representative offices for non-U.S. banks and fintechs for entry into the U.S. market as well as in connection with an internal reorganization.

Equity and non-equity investments, control analysis*

Conducted control analyses under the Federal Reserve's control framework for bank investments in fintechs and other companies and non-bank investments in banks, bank holding companies, and non-bank affiliates.

Examinations*

Navigated Federal Reserve, OCC, FDIC, and other examinations to explain business practices, minimize criticisms and misunderstandings, and reach a favorable and sound outcome.
*Denotes an attorney's experience prior to joining Davis Wright Tremaine
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Admitted to Practice

  • District of Columbia
  • New York

Education

  • J.D., The George Washington University Law School, 2014
  • B.A., International Affairs, The George Washington University, 2007
  • Certification, International Diploma, Sciences Po, 2006

Languages

  • French

Memberships & Affiliations

    • Director, Women in Housing and Finance
    • Co-chair, Enforcement Subcommittee, Banking Law Committee, American Bar Association
    • Banking Editorial Board, Law360

Professional Recognition

    • Recommended Lawyer, Finance – Financial Services Regulation, The Legal 500, 2024
    • Honoree, Women in Housing and Finance, 2024

Background

    • Counsel, Venable LLP, Washington, D.C., 2023-2024
    • Associate, Buckley LLP, Washington, D.C., 2021-2023
    • Associate, White & Case LLP, Washington, D.C., 2017-2021
    • Associate, Mayer Brown, Washington, D.C., 2014-2017
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Publications
May/June 2025
Publications
Co-author, "OCC Reverts Prior Merger Rules," FinTech Law Report, Thomson Reuters Read More
bank building
05.12.25
Insights
OCC Fintech Charter
OCC Reverts to Prior Merger Rules Read More
Publications
04.28.25
News
Quoted in "Higher asset thresholds, new resolution plan rules set to ease burdens on banks," S&P Global Read More External Link
Publications
04.22.25
Publications
"Ending the separation of banking and commerce myth," American Banker Read More External Link
treasury department building
04.15.25
Insights
Reg Reform Update – Financial Regulations To Be Clarified or Repealed Read More
Publications
March/April 2025
Publications
Co-author, "New Administration Outlook: An Opening For A National Payments/Fintech Charter-and A Pathway To Financial Modernization?" Fintech Law Report Read More
03.29.25
News
Quoted in "Goodbye, Reputation Risk," The Slant
Blank Paper Check
03.28.25
Insights
The Future of Government Payments – No More Paper Checks Later This Year Read More
Publications
03.14.25
News
Quoted in "Banks want federal regulators to better coordinate, not necessarily consolidate," S&P Global Read More External Link
notebook on conference table
03.14.25
Insights
Reintroduction of Bill To Speed Up BHCA and HOLA Applications Read More
Webinar
03.14.25
Webinars
Bank Regulatory
"Using AI and Other Modern Tech: Analyzing the FDIC Pause Letters," RegReform, Davis Wright Tremaine Webinar Read More
bank building
03.12.25
Insights
Senate Moves To End "Operation Choke Point" De-Banking With New Bill—But More Protections Are Needed Read More
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