Brendan M. Clegg | People | Arnold & Porter

Brendan Clegg represents national and state-chartered banks, credit unions, and financial services providers in a variety of regulatory, transactional, licensing, and enforcement matters before the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, the Federal Reserve Board, the Consumer Financial Protection Bureau, the Financial Crimes Enforcement Network, the National Credit Union Administration, and state banking regulators and attorneys general.

Brendan assists clients with preparing and submitting applications to regulators for approval of a range of novel and complex transactions and activities, including mergers and acquisitions. He advises financial services companies on an array of safety and soundness, consumer compliance, BSA/AML, risk management, and corporate governance matters.

Brendan provides strategic advice on regulatory interactions and examinations, and counsels boards and management on corrective actions to address supervisory findings and criticism. Brendan also represents banks and non-banks, as well as their directors and officers, in enforcement actions, administrative proceedings, and investigations initiated by state and federal agencies.

Before his career in private practice, Brendan served as an attorney in the OCC’s Enforcement Division.

Focus Areas

Experience

National bank in its acquisition of a state-chartered bank in Illinois and a state-chartered bank in its acquisition of a bank in Michigan.*
Mid-size regional bank in its acquisition of a financial technology company.*
State-chartered savings banks and trust companies, and federal savings banks, in their charter conversions to OCC-supervised national banks.*
National bank in its merger-of-equals with another national bank in New York.*
State-chartered banks and savings banks in their sales to state and national banks in Pennsylvania, California, Wisconsin, and New York.*

Federal savings bank in its acquisition of a title insurance agency.*
National bank in its acquisition of an equipment finance lender.*
Regional state-chartered bank in its multi-state sale of branches to another regional bank.*
Banks and investor groups in evaluating the implications under the Bank Holding Company Act and the Change in Bank Control Act for various acquisition and investment structures.*
Federal and state credit unions in their acquisitions of community banks in Arizona, Washington, New Mexico, Michigan, and California.*

*Represents experience with previous employer.

Regional bank in implementing enhancements to its Flood Disaster Protection Act compliance program.*
Numerous national and state banks in designing and updating policies and procedures related to transactions with affiliates (Reg. W) and loans to insiders (Reg. O).*
Financial technology companies and payments companies on compliance with federal and state money transmitter and MSB licensing regimes.*
State-chartered bank in its internal investigation of board compliance with internal policy.*
National bank in its internal review of BSA/AML compliance program and remediation of compliance gaps.*

Community banks in the development of bank-fintech partnership agreements, including deposit placement services.*
Large community bank in performing a fair lending risk assessment.*
Public banks in preparing their securities filings regarding disclosure of information related to enforcement and regulatory issues.*
Regional bank regarding strategic options for company reorganization and consolidation of affiliates.*
Foreign banking organizations regarding chartering options and licensing regimes for entering the U.S. market.*

*Represents experience with previous employer.

State-chartered banks, in enforcement proceedings and appeals before the FDIC related to safety and soundness and consumer compliance matters.*
Several community federal savings banks, defending enforcement actions initiated by the OCC related to safety and soundness issues and BSA/AML compliance.*
Regional bank, in its OCC appeal related to material supervisory determinations.*
Directors and senior executive officers of banks in Texas, California, and Louisiana in prohibition, cease-and-desist, and civil money penalty actions initiated by the OCC.*
State-chartered bank in Minnesota in negotiating the termination of an existing enforcement action.*

Numerous regional and community banks in devising action plans to address supervisory criticisms and matters requiring attention, including those related to BSA/AML and OFAC compliance.
Large financial services provider, in a parallel investigation conducted by the CFPB and multiple state AGs.
Auto finance companies, in responding to information requests by the FTC and CFPB.
Community banks in troubled condition status in their applications to make golden parachute payments under Part 359.

*Represents experience with previous employer.

Perspectives

August 24, 2026

Arnold & Porter Strengthens Financial Services Bench with Addition of Partner Brendan Clegg in Washington, D.C.

Credentials

Education

J.D., College of William and Mary Law School, 2012, summa cum laude
B.A., Colgate University, 2008, magna cum laude

Admissions

District of Columbia
Virginia

Government & Military Service

Attorney, Enforcement Division, Office of the Comptroller of the Currency (2013-2017)

Clerkships

U.S. District Court, Eastern District of New York, The Honorable Tucker L. Melancon (2012-2013)

Activities

Vice Chair of the Enforcement, Insider Liability, and Troubled Banks Subcommittee, ABA Banking Law Committee (2023-present)