David F. Freeman, Jr. | People

David Freeman represents financial institutions, investment managers, and broker-dealers on banking and securities regulatory issues, legislation, mergers and acquisitions, private investment funds, and new product development and documentation. As part of his practice, David advises domestic and foreign banks, investment management firms, and broker-dealers on compliance with state and federal banking and securities laws, federal commodities laws, and SRO rules.

Focus Areas

Experience

Developing and documenting bank deposit products and broker sweep arrangements.
Negotiating financial vendor services agreements.
Development of investment advisory, custody and client services form agreements.
Creation and operation of private investment funds, common trust funds and collective funds.
Advising client financial institutions and funds on services agreements, risk disclosures and regulatory issues associated with digital assets.

Representation of a large money market fund sponsor on rulemaking and public policy matters related to proposed changes in the U.S. and Europe to the regulation of money funds.
Advocating on behalf of banking organizations on the Volcker Rule, the LCR Rule and mortgage lending rules under the Dodd-Frank Act.

Obtaining or expanding bank and securities firm approvals to conduct business, including charters, licenses, registrations, approval orders, regulatory interpretations and membership agreements.
Advising clients on regulatory and policy matters involving the Financial Stability Oversight Council (FSOC), Federal Reserve Board, Federal Deposit Insurance Corporation (FDIC), Office of the Comptroller of the Currency (OCC), Financial Stability Board, International Organization of Securities Commissions (IOSCO), state bank and securities regulators, the Securities and Exchange Commission (SEC) and the Financial Industry Regulatory Authority (FINRA).
Developing, enhancing, documenting, and automating supervisory and compliance systems and internal policies and procedures regarding banking and securities operations.

Acquisitions and sales of banks and trust companies, broker-dealers, investment advisers, and business units, and private investments in financial services firms.

Perspectives

April 1, 2024

Arnold & Porter Discusses OCC, FDIC Policy Statements on Bank Merger Scrutiny

The CLS Blue Sky Blog

March 26, 2024

OCC and FDIC Each Propose Policy Statements Focused on Greater Scrutiny of Bank Merger Transactions

Advisory

February 29, 2024

Basics Of Bank Regulators' Push For Discount Window Use (pdf)

Law360

March 2024

Federal Deposit Insurance Corporation Proposes Large Bank-Like Corporate Governance and Risk Management Standards for FDIC-Supervised Depository Institutions With US$10 Billion or More in Assets (pdf)

The Banking Law Journal

February 1, 2024

Regulators Discuss Liquidity Risk Management, Operational Readiness, and the Federal Reserve’s Discount Window

Advisory

More

Recognition

IFLR1000

"Highly Regarded" — Financial Services Regulatory, Investment Funds (USA) (2019-2023)

The Legal 500 U.S.

"Leading Lawyer" Financial Services Regulation (2023)
Financial Services: Regulatory (2011-2022)
Financial Services: Litigation (2016-2017, 2021-2022)
Fintech (2021-2022)

Chambers USA

Financial Services Regulation: Banking — Compliance (Nationwide) (2008-2023)
Financial Services Regulation: Broker Dealer — Compliance (Nationwide) (2022-2023)

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Credentials

Education

J.D., University of Virginia School of Law, 1987
M.B.A., University of Virginia, 1987
B.A., University of Virginia, 1981

Admissions

District of Columbia
Virginia

Activities

Board of Advisors, UNC School of Law, Center for Banking & Finance