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About the Legal Division

OCC Chief Counsel's Office

The Chief Counsel's Office (CCO) manages seven legal practice areas from the Washington headquarters office. There are also general practice offices in each of the four district locations.


 

Chief Counsel's Office 202-649-5400
Amy Friend Senior Deputy Comptroller and Chief Counsel
Daniel P. Stipano Deputy Chief Counsel
Karen Solomon Deputy Chief Counsel

The primary mission of the OCC’s Chief Counsel’s Office is to provide high quality and timely work in support of the agency’s goals and strategic objectives, including the following:

  • Provide legal analyses and interpretations, consistent with law and regulation, that encourage responsible innovation in the banking industry to meet the needs of consumers, businesses, and communities; and that support a safe and sound, vibrant, and diverse system of national banks and federal savings associations.
  • Provide legal support for administrative actions to enforce compliance with applicable laws and regulations and safe and sound practices by national banks, federal savings associations, and institution-affiliated parties, as necessary.
  • Provide legal advice on the application of consumer laws and regulations to ensure that consumers have fair access to financial services and are treated fairly.
  • Provide legal counsel and support on a broad range of federal laws that apply to national banks’ and federal savings associations’ capital markets and trust/fiduciary activities.
  • Analyze legislation affecting the national banking system, federal savings associations, and OCC agency operations.
  • Provide drafting support and legal advice with respect to OCC rulemakings.
  • Provide legal advice on international banking issues and prepare cross-border agreements to support collaboration with international regulators on the identification of systemic risk and the efficient supervision of financial systems.
  • Represent the Comptroller of the Currency in litigation involving OCC's decisions and operations, and the National Bank Act.
  • Provide legal support for timely and sound decisions on corporate applications in support of a vibrant, diverse, and innovative system of national banks and federal savings associations.
  
Administrative & Internal Law (AIL) 202-649-5560
David Kane Director
Patricia Grady Assistant Director

The Administrative and Internal Law Division (AIL):

  • Serves as the OCC’s counsel on a variety of matters affecting the administration of the Agency’s business:
    • Provides counsel to the OCC’s Office of Management regarding procurement matters (including bid protests), lease negotiations and lease terms for offices across the United States, and financial matters, including federal tax law and federal travel regulations;
    • Provides advice regarding FOIA appeal decisions, administration of the Privacy Act, delegations of authority, and information sharing and disclosure;
    • Provides counsel to OCC managers on employment law, labor relations law and collective bargaining issues; represents the OCC at labor arbitrations and at administrative proceedings before the Federal Labor Relations Authority;   
    • Provides counsel to EEO staff and OCC managers regarding equal employment law; and
    • Provides guidance to the Chief Counsel in administering the OCC ethics program.
 
Bank Activities & Structure (BAS) 202-649-5500
Eric Thompson Director
Kevin Corcoran Assistant Director
Eden Gray Assistant Director
Valerie Song Assistant Director

The Bank Activities and Structure Division (BAS):

  • Serves as the OCC’s counsel on a broad range of activities and corporate structures of national banks, federal savings associations and federal branches and agencies: 
    • Advises licensing on matters including charters, mergers and acquisitions, changes in control, operating and financial subsidiaries, and non-controlling investments in other entities;
    • Provides counsel relating to the ongoing activities of national banks and federal savings associations that could present operational risks affecting their safety and soundness, including electronic banking, third-party service providers, lending limits, affiliate transactions, and real estate and leasing activities;
    • Provides legal support with respect to problem bank and resolution matters in both domestic and cross-border contexts, including receiverships, conservatorships, and voluntary liquidations; and
    • Coordinates with other federal financial agencies, including the Federal Reserve Board, the Federal Deposit Insurance Corporation, the Federal Financial Institutions Examination Council, and the Financial Stability and Oversight Council on resolution issues.
  
Community and Consumer Law (CCL) 202-649-6350
Donna Murphy Director
Ken Lennon Assistant Director

The Community and Consumer Law Division (CCL):

  • Serves as the OCC’s counsel on a wide range of consumer-related issues:
    • Advises the OCC’s supervisory, compliance, licensing, enforcement, community affairs, and customer complaint resolution units regarding consumer protection, fair lending, and community development and Community Reinvestment Act matters, as they apply to national banks and federal savings associations;
    • Advises other legal divisions and lines of business  regarding fair access to bank services, bank community development powers and community reinvestment activities; and
    • Collaborates internally with OCC lines of business and externally with the Consumer Financial Protection Bureau, the other federal banking agencies, and other responsible governmental agencies regarding the development, implementation, and consistent application of consumer-related regulations and policy guidance.
   
Enforcement and Compliance (E&C) 202-649-6200
Ellen Warwick Director
Linda Bridgman Principal Assistant to the Director for Special Investigations
Monica Freas Assistant Director
William Jauquet Assistant Director
Larry Keen Assistant Director
Gerard Sexton Assistant Director

The Enforcement and Compliance Division (E&C):

  • Serves as the OCC’s counsel for formal investigations and enforcement actions:
    • Conducts investigations;
    • Litigates all non-delegated enforcement actions, including civil money penalties, suspensions and removals, temporary cease and desist orders, and other administrative enforcement actions;  
    • Refers criminal acts involving institution-affiliated parties to the Department of Justice (DOJ); and
    • Coordinates with DOJ, the federal banking agencies, and other regulatory agencies, including the Financial Crimes Enforcement Network, the Securities and Exchange Commission, and the Consumer Financial Protection Bureau on law enforcement efforts involving national banks and federal thrifts.
 
Legislative & Regulatory Activities (LRA) 202-649-5490
Stuart Feldstein Director
Jamey Basham Assistant Director
Deborah Katz Assistant Director/Legislative Counsel
Patrick Tierney Assistant Director

The Legislative and Regulatory Activities Division (LRA):

  • Serves as the OCC’s counsel on legislative and regulatory matters:
    • Develops and drafts the OCC's regulations and provides legal counsel for the agency's compliance with the various federal statutes and, where applicable, executive orders that govern the rulemaking process;
    • Monitors pending legislation of significance to national banks, federal savings associations, or the OCC, and provides legal support for the agency's legislative work;
    • Provides legal advice on international banking issues relating to foreign banks' federal branches or agencies in the United States and the foreign operations of national banks and federal savings associations;
    • Provides legal advice on issues relating to national banks’ and federal savings associations' regulatory capital requirements; and
    • Provides legal advice on issues relating to cybersecurity as it affects national banks and federal savings associations.
  
Litigation (LIT) 202-649-6300
Horace Sneed Director
Greg Taylor Assistant Director

The Litigation Division (LIT):

  • Serves as the OCC’s counsel in a variety of forums:
    • Represents the OCC in court;
    • Represents the OCC in the administrative phase of personnel actions (e.g., EEO, Merit Systems Protection Board);
    • Administers the OCC's regulations regarding confidential supervisory information;
    • Advises the Comptroller regarding administrative law judge decisions appealed to the Comptroller, and drafts the Comptroller's decision document;
    • Provides litigation risk advice; and
    • Participates in the preparation of the legal memoranda necessary for problem bank resolutions.
  
Securities & Corporate Practices (SCP) 202-649-5510
Ted Dowd Director
Suzette Greco Assistant Director

The Securities and Corporate Practices Division (SCP):

  • Serves as the OCC’s counsel on a broad range of banking, securities, commodities, and corporate governance matters:
    • Drafts legal memoranda, opinions, and interpretive letters;
    • Advises examiners, policy staff, and banks on matters including capital markets activities (e.g., commodities, securities, derivatives, central counterparties, and structured finance); asset management activities (e.g., trust, fiduciary, custody, and prime brokerage); Dodd–Frank Act provisions (e.g., the Volcker Rule and Title VII’s amendments to the securities laws and the Commodity Exchange Act); accounting; annuities, insurance and debt cancellation contracts; and tying;
    • Provides subject matter expertise with respect to analyzing legislation, and enforcement and litigation matters; and
    • Coordinates with the Securities and Exchange Commission, the Commodity Futures Trading Commission, the federal banking agencies, and other regulatory agencies regarding rulemaking, legal interpretations, etc.
  
District Counsel Offices
Northeastern District Office (NEDO) 212-790-4010
Jonathan Rushdoony District Counsel
James Porreca Assistant District Counsel
   
Southern District Office (SODO) 214-720-7012
Randy Ryskamp District Counsel
Javier Maymir Assistant District Counsel
   
Central District Office (CEDO) 312-360-8805
Damon J. Savoy Assistant District Counsel
   
Western District Office (WEDO) 720-475-7630
Lance Cantor District Counsel
Jimmy Singh Assistant District Counsel

The District Legal Offices:

  • Serve as frontline legal advisors to the OCC’s District Deputy Comptrollers and bank examiners in the OCC’s District Offices:
    • Provide legal advice to large, mid-size and community bank, and federal branch and agency examination teams;
    • Provide banking companies, bank counsel, and law firms with information and clarification regarding OCC rules, policies, and other matters affecting their institutions or clients;
    • Liaise with representatives of state banking departments and other local offices of federal and state agencies regarding issues of mutual interest;
    • Provide legal support on midsize and community bank enforcement actions;
    • Conduct legal training programs for examiners;
    • Represent the Law Department as speakers at seminars and conferences; and
    • Prepare a variety of corporate opinions and legal advisory letters.
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