Financial Services

We advise clients on a broad range of public policy matters impacting the financial services sphere and we have particularly strong expertise in the property/casualty and life insurance sectors. We have been closely involved with the formulation, implementation and reform of the Dodd-Frank Act, the Terrorism Risk Insurance Act and the CARES Act, and offer clients strategic advice and counsel based on our long experience and ties with key policymakers. Our practice also has particular experience with financial services policy matters as they apply on both sides of the Atlantic, and our team has been instrumental in key cross-border negotiations and policy implementation.Our financial services practice in the legislative and public policy sphere offers clients important strategic advice and counsel based on our long experience and ties with key policymakers. Our lawyers have represented the financial services industry (both companies and trade groups) on a variety of matters relating to the Dodd-Frank Act, including Title I (systemic risk), the development of Title V (creation of the Federal Insurance Office and the Nonadmitted and Reinsurance Reform Act) and Title VI (regulation of savings and loan holding companies and the Volcker Rule). We have been closely involved with the recent efforts to reform the Dodd-Frank Act, including the Financial CHOICE Act, as well as the Economic Growth, Regulatory Relief, and Consumer Protection Act.

Experience Highlights

  • Coalition to Insure Against Terrorism (CIAT), a broad-based business coalition of 85 major trade and professional associations—including the US Chamber of Commerce, National Association of Real Estate Investment Trusts, The Real Estate Roundtable, National Association of Manufacturers, and all of the major league professional sports associations—in fashioning and securing enactment of a post-9/11 federal terrorism insurance backstop to the Terrorism Risk Insurance Act of 2002 (TRIA) and in subsequent TRIA reauthorization campaigns; most recently the successful 2019 reauthorization.
  • The Real Estate Roundtable in preparing strategic plan for TRIA reauthorization in 2019-2020.
  • Lloyd's of London before Congress and the executive branch on a wide range of legislative and regulatory issues that would affect its trading position in the United States. Current work includes implementation of rules relating to private flood insurance, the 2019 reauthorization of TRIA, potential revisions to federal Surety Bond Program regulations, and pandemic response proposals.
  • Lloyd's of London in connection with Title V of the Dodd-Frank Act and subsequent successful efforts to secure a US-EU "covered agreement" on insurance/reinsurance prudential matters.
  • American Property Casualty Insurance Association (APCIA) on developing a strategy relating to the regulatory implementation of private flood insurance acceptance requirements, drafting proposed regulations and executive order designed to implement this strategy, and further refining to secure a broad industry consensus on the proposal culminating in multi-agency advocacy that produced a promulgated final rule achieving much of the client’s goals.
  • APCIA in connection with preparation of pandemic response proposals in both chambers of Congress.
  • Mid-sized bank subject to FDIC macroprudential supervision in connection with the proposed increase of the SIFI asset threshold from $50 billion to $250 billion in the Senate's Dodd-Frank 2018 reform bill [S. 2155].
  • Mid-sized bank in securing a favorable tax treatment (pass-through rate) for a particular banking ownership structure.
  • Federated Investors, one of the world's largest managers of money market mutual funds (MMFs), in advocacy before the NAIC and state regulators to obtain "cash equivalency" treatment of MMFs in insurer financial statements.
  • Dutch Association of Insurers regarding proposals in recent Congresses that would create a new cause of action for Holocaust survivors or kin to sue in federal courts the US affiliates of European insurers that were doing business during 1933–45.
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