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The Volcker Rule 2019: What It Means for Financial Institutions and Markets

Speaker(s): Andrew R. Bernstein, Anna M. Harrington, Camille L. Orme, Cantrell Dumas, Cecily Boggs, Curtis K. Tao, Daniel B. Nelson, Gabriel D. Rosenberg, Gregg L. Rozansky, Heather S. Cruz, Joerg Riegel, Michael A. Mazzuchi, Phillip S. Gillespie, Robert Toomey, Satish M. Kini, Sean D. Campbell, Stephanie E. Webster, Tabitha Edgens, Ulrich Hannich, Yosef Ibrahimi
Recorded on: May. 2, 2019
PLI Program #: 252422

Satish Kini is Chair of Debevoise’s Banking Group and a member of its Financial Institutions Group. Mr. Kini advises on a wide range of regulatory and transactional banking issues.

For example, he has:

  • represented large financial services firms in transactional matters, including to secure regulatory approvals for transactions from U.S. federal and state bank regulatory agencies and to develop compliance frameworks for various business combinations;
  • counseled banks, insurers, asset managers and securities firms in a broad range of regulatory and compliance issues, ranging from the Volcker Rule to affiliate transactions, anti-money laundering, economic sanctions and data privacy/security;
  • represented clients in adversarial proceedings before the federal bank regulatory agencies and the Consumer Financial Protection Bureau, including in enforcement proceedings and in adverse examination contexts; and
  • advised clients on regulatory and compliance issues arising out of cross- border transactions and outsourcing arrangements, including with respect to sanctions and money laundering issues.

In the context of these matters, Mr. Kini has led internal fact investigations of clients (involving allegations of data breaches/fraud, money laundering and sanctions compliance issues) and advised clients on compliance governance and structuring. He also has briefed senior business decision-makers and boards of directors, based in the United States and abroad, on important regulatory, enforcement and investigations matters.

Mr. Kini has represented a wide range of firms (including banks, insurers, securities broker-dealers and asset managers) and leading industry trade associations on regulatory reform issues, including those arising out of the Dodd-Frank Act, and has assisted clients to participate in the policymaking process before federal regulators. He has helped to create industry coalitions to advocate for regulatory positions and to arrive at consensus interpretations on difficult issues. He also has testified on Dodd-Frank issues before Congress and has represented clients on Dodd-Frank and other matters before the federal banking agencies, the U.S. Securities and Exchange Commission, the Financial Stability Oversight Council and the U.S. Treasury Department and its Financial Crimes Enforcement Network (“FinCEN”) and Office of Foreign Assets Control (“OFAC”).

Mr. Kini received his B.A. magna cum laude from Colgate University in 1985. He received his J.D. from Columbia University School of Law in 1992, where he was a Harlan Fiske Stone Scholar, a John M. Olin Fellow in Law and Economics and the Managing Editor of the Columbia Law Review. He is a member of the District of Columbia and the New York Bars

Anna M. Harrington serves as Senior Vice President and Associate General Counsel on the regulatory team of The Bank Policy Institute where she leads BPI’s regulatory advocacy efforts on capital and other key prudential regulatory matters. She brings over a decade of public service and private sector experience, including working in both legal and policy roles.

Previously, she was a member of the Financial Institutions Practice Group at WilmerHale where she advised clients on complex regulatory and transactional matters.  Prior to WilmerHale, Ms. Harrington was the U.S. Head of Bank Regulatory Policy at Barclays.  In this role, she led and managed the development of U.S. bank regulatory policy priorities and strategy. 

Ms. Harrington previously served in both the Legal Division and in the Division of Supervision and Regulation of the Board of Governors of the Federal Reserve System where she was responsible for developing and implementing policy across a number of post-crisis Dodd-Frank Act rulemakings.  Ms. Harrington also analyzed numerous proposals, applications, and issues arising under U.S. banking laws, including the Bank Holding Company Act, the Change in Bank Control Act, the Federal Reserve Act, and the International Banking Act and related regulations. 

Ms. Harrington earned a J.D. degree, magna cum laude, from Boston College Law School, where she was elected to the Order of the Coif and served as a Note Editor on the Boston College Law Review.  She earned an A.B. degree, magna cum laude, in Economics from Harvard College.  Ms. Harrington is a member of the New York bar.

Camille Orme is a partner in the Firm’s Financial Services Group. Ms. Orme represents U.S. and non-U.S. financial institutions on a range of regulatory, corporate and transactional matters. Recent areas of focus include advising financial institutions on responding to the significant changes in the regulatory landscape following the financial crisis, including the Volcker Rule, the consequences of being designated systemically significant, the interplay of U.S. and non-U.S. regulatory changes, restructuring global businesses in light of shifting regulatory requirements and standards, the Federal Reserve’s enhanced prudential standards, and the OCC’s guidelines establishing heightened standards for large banking organizations.

Ms. Orme’s regulatory practice also includes advice regarding controlling and non-controlling investments by and in banking organizations, bank activities powers, the affiliate transaction rules, restrictions on insider transactions, restrictions on depository institution management interlocks, brokered deposit regulations, and broker-dealer push-out.
In addition, Ms. Orme has advised on numerous transactional matters and corporate and disclosure matters. She also has experience with derivatives regulation and the formation and designation of electronic exchanges.
Ms. Orme has been a speaker on U.S. regulatory reform and other bank regulatory issues, including at conferences and programs hosted by the American Bar Association, the Institute of International Bankers, Practising Law Institute, the Washington, D.C. Bar Association and the Association of the Bar of the City of New York. She is a Co-Chair of the ABA Banking Law Committee International Banking Subcommittee, a member of the Banking Law Committee of the Association of the Bar of the City of New York, and a past member of the Association of the Bar of the City of New York Committee on Futures Regulation. 
Ms. Orme serves as Co-Chair of the Firm’s Women’s Initiative Committee and an Associate Development Partner for the Firm’s Financial Services Group. She has been recognized for her work in Chambers USA as an Up and Coming lawyer in Financial Services Regulation: Banking Compliance and was awarded the Best in Financial Regulation award at Euromoney Legal Media Group's Americas Women in Business Law Awards in 2016.

Cantrell Dumas is a Special Counsel in the Division of Swap Dealer and Intermediary Oversight at the Commodity Futures Trading Commission where he is responsible for drafting regulations, orders, and guidance applicable to CFTC’s registered Swap Dealers.

Prior to joining the CFTC, Cantrell was an attorney at the Federal Deposit Insurance Corporation.  Prior to the FDIC, Cantrell was an associate with a major law firm.

Cantrell is a graduate of Columbia Law School and the University of South Alabama.

Curtis K. Tao is a Managing Director and Deputy General Counsel at Citigroup, advising on bank and bank holding company regulatory matters at Citi from 2005 to 2009, and also since he returned to Citi in November 2011. Curtis heads Citi’s Bank Regulatory Legal group, reports directly to Citi’s General Counsel, and serves on the Legal Department’s Management Committee. Curtis is also a member of Citi’s Asian Heritage Affinity Steering Committee, and sponsors the Citi Legal Department Diversity Council.

From 2009 to November 2011, Curtis was an Associate General Counsel at Goldman Sachs, also advising on bank and bank holding company regulatory matters. 

From 2001 to 2005, Curtis was an associate at the law firm of Cleary, Gottlieb, Steen & Hamilton LLP. Curtis clerked for Chief Justice Deborah T. Poritz of the New Jersey Supreme Court for the 2000-2001 term, and for Judge John L. Coffey of the Federal Court of Appeals for the Seventh Circuit for the 1999-2000 term. Curtis received his J.D. from Rutgers School of Law (1999), and his B.A. from Rutgers University (1995). Curtis is admitted to practice in New York and New Jersey.

Daniel B. Nelson is a Senior Vice President and Senior Company Counsel at Wells Fargo, where he focuses on bank regulatory matters.  As one of the first in-house lawyers responsible for conformance with the Volcker Rule’s final implementing regulations, Dan has been a leading voice on the rule and has had a major role in shaping its understanding and interpretation within the financial industry.  In his current role, Dan continues to advise on Volcker-related matters at the enterprise level.

Gabriel Rosenberg is a partner in Davis Polk’s Financial Institutions Group and a member of the firm’s Regulatory Enforcement and Investigations and Trading and Markets practices. He advises financial institutions, corporations and industry groups on all aspects of financial regulatory issues, ranging from the impact of financial regulatory reform on business strategy to implementation challenges to enforcement and supervision.

Mr. Rosenberg advises on subjects including derivatives regulation, the Volcker Rule, capital and liquidity requirements and resolution planning. His practice also involves the use of technology to help market participants understand and comply with regulatory obligations and the impact of financial regulatory reform.

In addition to his full-time practice, Mr. Rosenberg is a frequent writer, commentator and lecturer on financial regulatory reform issues. He is co-editor of the first comprehensive treatise on the new swap regulatory regime, and has held academic appointments at Yale Law School, the Yale School of Management and the Haas School of Business at UC Berkeley.

Gregg L. Rozansky current serves as Senior Vice President, Senior Associate General Counsel for the Bank Policy Institute. Prior to joining BPI, Mr. Rozansky served as Managing Director and Senior Associate General Counsel of The Clearing House. In that capacity, Mr. Rozansky led the policy efforts of The Clearing House on a wide array of bank regulatory, compliance and corporate governance-related issues impacting large financial institutions.  Mr. Rozansky is a frequent presenter on bank corporate governance and regulatory issues at leading financial industry events and has written extensively on the regulation of major banking institutions and regulatory reform, including the Dodd-Frank Act.

Prior to joining The Clearing House in 2013, Mr. Rozansky advised financial institutions on U.S. bank regulatory and compliance issues in private practice at Cleary Gottlieb Steen & Hamilton and Shearman & Sterling, focusing on cross-border transactions and the implications of U.S. and global regulatory reforms and developments. Mr. Rozansky is a graduate of Harvard Law School and earned his B.A. in economics and government at Cornell University. At Harvard, he held a position as a Teaching Fellow in the Department of Economics.

Heather Cruz represents investment advisers and investment banks in connection with the structuring and distribution of U.S. and international private investment products, including private equity funds, multi- and single-strategy hedge funds, real estate funds, infrastructure funds, credit and distressed debt funds, as well as fund of funds. She also advises clients on the establishment, operation and sale of investment adviser and broker-dealer businesses.

With respect to private investment funds, Ms. Cruz advises clients on a broad spectrum of legal issues and considerations relating to the establishment and operation of private investment funds marketed and operated on a global basis. She also represents institutional investors seeking to invest in private investment funds and in investment advisers.

In addition, Ms. Cruz has extensive experience providing regulatory advice to broker-dealers and investment advisers, including regarding compliance with various aspects of the Dodd-Frank Act, with a particular focus on the Volcker Rule. She also advises on a range of issues relating to U.S. Investment Advisers Act, the U.S. Investment Company Act, and the rules and regulations of FINRA.

Ms. Cruz has repeatedly been selected for inclusion in Chambers Global: The World’s Leading Lawyers for Business and Chambers USA: America’s Leading Lawyers for Business. She also was named in Expert Guides – The World’s Leading Lawyers Chosen By Their Peers, The Best Lawyers in America and as a worldwide leading lawyer in Euromoney Institutional Investor’s 2015 Banking Finance and Transactional Expert Guide.

Ms. Cruz received her J.D. from New York University School of Law and her M.B.A. from NYU Leonard Stern School of Business. She also holds a B.S. from University of Southern California. Ms. Cruz is member of the Private Investment Funds Committee of the Association of the Bar of the City of New York.

Joerg Riegel is the Head of U.S. Regulatory Initiatives, responsible for a variety of regulatory change and advocacy matters. He is also the lead lawyer on the Volcker Rule at Société Générale. In this capacity, he was responsible for the legal aspects of the global implementation of the Volcker Rule across all trading and funds aspects.

Prior to joining Société Générale, Mr. Riegel was a Director and Senior Counsel at RBS. Before joining RBS, Mr. Riegel was an associate at Davis Polk, where he represented financial institutions on financial regulatory matters, as well as with respect to OTC and capital markets transactions.

Mr. Riegel holds a Master of Laws from Columbia University, where he was a James Kent scholar, a JD equivalent in German law from the University of Freiburg, Germany, and a DEUG in French law from the University Jean Moulin, Lyon, France. He is a member of the New York bar.

Phillip S. Gillespie joined SSGA in June 2008 as Executive Vice President and General Counsel. In that role, Phil is responsible for the global legal affairs of SSgA and oversees a team of experienced attorneys, paralegals and assistants located in Boston, London, Paris, Tokyo, Montreal, Hong Kong and Sydney. He is a member of SSgA's Executive Management Group.

Phil joined SSgA from OppenheimerFunds, Inc. (OFI) where he was Senior Vice President and Deputy General Counsel and responsible for the day-to-day operations of OFI's Legal Department. Prior to joining OFI in 2004, Phil was First Vice President - Legal Advisory at Merrill Lynch Investment Managers (MLIM), where he managed a team of attorneys and paralegals providing legal services and oversight for MLIM's U.S. based investment teams, operations and its U.S. registered fund business.

From 1993 to 1997, Phil was an attorney with the U.S. Securities and Exchange Commission (SEC) in its Washington, D.C. headquarters holding posts as Senior Counsel in the Legal Policy and Counseling Group of the SEC's Office of the General Counsel and as Senior Counsel in the Office of Chief Counsel of the SEC's Division of Investment Management.

Prior to joining the SEC, Phil was an associate in the corporate finance practice of the Seattle law firm, Perkins Coie, and started his legal career as a law clerk to the Honorable Charles Clark, Chief Judge of the U.S. Court of Appeals for the Fifth Circuit.

Phil is a graduate of Georgetown University's School of Foreign Service and earned his JD, magna cum laude, from Tulane Law School. He is a native of the state of Mississippi.

Robert Toomey is Managing Director and Associate General Counsel, Head of Capital Markets at SIFMA. Mr. Toomey supervises the capital markets activities of SIFMA and coordinates SIFMA advocacy around the Volcker Rule.

Prior to joining SIFMA’s predecessor, the Bond Market Association, in September 2004, Rob served from 1995 as Counsel at the Federal Reserve Bank of New York, principally supporting the NY Fed’s Markets Group in connection with US Treasury activities, open market operations, primary dealer relationships and foreign exchange. Immediately prior to joining the NY Fed, Rob was a Special Counsel at the Securities and Exchange Commission in the Division of Corporation Finance. Prior to the SEC he was an Associate at the law firm of Reid & Priest.

Rob has a BA from Haverford College and a JD from Fordham University School of Law.

Sean D. Campbell is the Executive Vice President, Director of Policy Research, at the Financial Services Forum.  He joined the Forum in April 2018.

Prior to joining the Forum, Dr. Campbell served as an Associate Director in the Federal Reserve Board’s Division of Supervision and Regulation and as a Deputy Associate Director in the Division of Research and Statistics. Dr. Campbell joined the Federal Reserve Board staff as a staff economist in June of 2004.  While at the Board, Dr. Campbell contributed to the development and design of an array of regulatory policy initiatives including stress testing and capital, derivative market regulation, and a number of Dodd-Frank Act reforms.

Dr. Campbell’s research focuses on financial risk management and the intersection between the macroeconomy and financial markets.  Dr. Campbell’s research has been published in a number of leading, peer-reviewed, academic journals including the Review of Financial Studies, the Journal of Financial and Quantitative Analysis and the Journal of Business and Economic Statistics.

Prior to joining the staff of the Federal Reserve Board, Dr. Campbell was an assistant professor of economics at Brown University.  Dr. Campbell has a Ph.D. in economics from the University of Pennsylvania and a B.A. in economics from the University of Massachusetts, where he graduated Phi Beta Kappa.

Stephanie E. Webster is General Counsel of the Institute of International Bankers.  Prior to joining the IIB, Stephanie was a Director and Counsel in the General Counsel division of Credit Suisse based in New York.  She was the head of the US Bank Regulatory & ERISA Legal group.  Ms. Webster joined Credit Suisse in January 2011.  Prior to that, she was an associate at the law firm of Linklaters in the financial regulations group, advising primarily on U.S. bank regulatory matters, and at the law firm of Goodwin Procter LLP in the financial services group.  Ms. Webster began her legal career at the law firm of Freshfields Bruckhaus Deringer LLP as an associate focused on international arbitration.  Ms. Webster received her J.D. from New York University School of Law and her B.A., with honors, from Brandeis University.  She is also an adjunct professor at Fordham University School of Law.

Tabitha Edgens is a Senior Attorney in the Chief Counsel’s Office, Securities and Corporate Practices Division, in the Office of the Comptroller of the Currency. In this role, Ms. Edgens advises OCC policymakers, senior managers, and examiners on a range of banking, securities, derivatives, and fiduciary matters, including Volcker Rule implementation.

Prior to joining the OCC, Ms. Edgens focused on bank regulatory matters as an associate with a major law firm.

Ms. Edgens is a graduate of Yale Law School and Tulane University.

Ulrich Hannich is an Executive Director and Americas Bank Regulatory Counsel at UBS, advising UBS on bank regulatory matters as well as the Volcker rule. Ulrich also managed UBS's global implementation of U.S swap dealer regulation and supported UBS's bond trading businesses. He is qualified to practice law in New York and Germany and studied law at Fordham University School of Law (LL.M. in Banking, Corporate and Finance Law), King's College London, UK (LL.M. in Intellectual Property Law), and Albert-Ludwigs University, Freiburg, Germany.

Yosef Ibrahimi is a director in the general counsel department of Credit Suisse. He heads the U.S. Bank Regulatory, ERISA, Benefits and U.S. Cross Border practice groups in Credit Suisse’s general counsel department. Mr. Ibrahimi was previously the lead lawyer advising Credit Suisse’s wealth and asset management businesses on U.S. banking laws. He has particular expertise on the interaction of banking laws to asset management activities. Mr. Ibrahimi is particularly focused on the Bank Holding Company Act, Volcker Rule, regulatory examinations, and legislative and regulatory advocacy. Before joining Credit Suisse, Mr. Ibrahimi was a senior associate at Skadden Arps, where he focused on restructuring and insolvency law. Before joining the firm, he clerked for a Justice of the Delaware Supreme Court.

Mr. Ibrahimi received his law degree from Cornell University and his undergraduate degree from the Macaulay Honors College at the City University of New York. He is a member of the New York and Delaware bars.

In December 2018, Cecily Boggs joined the Federal Reserve Board of Governors as a Senior Financial Institution Policy Analyst within the S&R Policy Development group. In this role, Ms. Boggs focuses on the policy interpretation and rulemaking processes related to market risk capital and the Volcker Rule.

From 2011-2018, Ms. Boggs served as Supervisory Policy Associate at the Federal Reserve Bank of New York. In that role, Ms. Boggs led FRBNY supervisory efforts on Volcker Rule implementation and contributed to international and domestic policy development on resolution.

Prior to joining the Federal Reserve, Ms. Boggs was a Financial Services Policy Analyst at The Cypress Group, LLC – a strategic advisory and advocacy firm focused on public policy issues related to finance.

Ms. Boggs has a BA in French Studies from Rice University and a certificate in International Relations from the Institut D'Études Politiques de Paris.

Andrew R. Bernstein is a Senior Special Counsel in the Office of Derivatives Policy in the Division of Trading and Markets, where he works on drafting new rules necessary to implement the OTC derivatives reforms in Title VII of the Dodd Frank Act. He also plays a leading role on the cross-divisional and interagency teams responsible for the Volcker Rule. In addition, Andrew provides interpretive advice on the regulatory treatment of novel derivatives products under the Securities Exchange Act of 1934, and administering new product provisions contained in the Dodd-Frank Act. Prior to holding his current position, Andrew was a Branch Chief in the Office of Chief Counsel and a Special Counsel in the Office of Clearance and Settlement, both of which are also in the Division of Trading and Markets. 

Prior to joining the SEC in 2010, Andrew practiced securities and corporate law at Sullivan & Cromwell LLP. Andrew received a Bachelor of Science from the College of Agriculture and Life Science at Cornell University in 1995, and a Juris Doctor, magna cum laude, from American University Washington College of Law in 2005.

Michael A. Mazzuchi is a partner based in the Washington, D.C. office of Cleary Gottlieb Steen & Hamilton LLP.

Mr. Mazzuchi’s practice focuses on corporate and securities matters, particularly domestic and international structured finance and derivatives matters.  He has extensive experience in mortgage and asset securitizations, collateralized bond obligation transactions, synthetic debt securities and repackagings, credit derivative transactions and interest rate, currency and equity derivatives.  He is distinguished as one of the leading lawyers by Chambers Global, Chambers USAThe Legal 500 U.S. and IFLR 1000: The Guide to the World’s Leading Law Firms. 

Mr. Mazzuchi joined the firm in 1992 and became a partner in 2001. He received a J.D. degree, magna cum laude, in 1992 from the University of Michigan Law School, where he was a member of the editorial board of the Michigan Law Review.  He received an undergraduate degree from the University of Michigan in 1989.

Mr. Mazzuchi is a member of the Bar in the District of Columbia.