Financial Services

Enforcement Counseling and Defense

We assist individuals and institutions—and their boards of directors and holding companies—with the negotiation of consent agreements, memoranda of understanding and other written settlements, the development of compliance programs, and the defense of enforcement actions in administrative and judicial proceedings, and in addressing financial reporting and disclosure issues presented by agency enforcement initiatives. We also represent officers and directors, accountants, and other professionals in actions by receivers of insolvent financial institutions and in shareholder suits.

We are experienced in such currently high-profile issues as subprime lending, vendor management, privacy, nontraditional lending products and practices, money laundering, bank secrecy, and various activities considered inconsistent with safe and sound practices. In addition, we have substantial experience representing individuals and entities who are alleged to have violated the control provisions of the Change in Bank Control Act, the Bank Holding Company Act and the Savings and Loan Holding Company Act. Many of our attorneys have served as senior enforcement officials or on the enforcement staffs of the federal banking agencies, the SEC, the CFTC, or the Department of Justice adding depth and insight to our representation of clients in enforcement matters.


Aurora Bank, FSB Enforcement counseling

Represented client in multiple enforcement matters.

Multi-billion dollar state-chartered bank Potential enforcement action

Represented client in connection with adverse examination findings.

Multi-billion dollar federal savings bank Consent order

Represented client in negotiation of an OCC-issued consent order to address alleged non-compliance with the Bank Secrecy Act and related anti-money laundering regulations.

Large depository institution Threatened fair lending enforcement

Advised client on remediation efforts and fair lending monitoring in connection with issues raised under the Equal Credit Opportunity Act and Regulation B.

Mid-sized national bank Regulation E remediation

Advised client in developing a plan of financial remediation of fees in connection with self-identified ACH transaction issues.


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