Anna M. Harrington

A former government regulator with a decade of experience in policymaking in both the Legal Division and Division of Supervision and Regulation at the Board of Governors of the Federal Reserve Board (FRB) and the former US head of bank regulatory policy at Barclays, Anna Harrington brings her experience and legal and policy insights to her practice advising clients and providing strategic advice on complex financial services regulatory and transactional matters. 

Ms. Harrington advises domestic and foreign banking organizations, private equity firms, and other fund clients on a wide range of regulatory and policy issues, including implementing regulations and interpretive letters, structuring and optimization strategies in the context of the FRB’s tailoring initiatives, Volcker proprietary trading and covered fund issues, and complex derivatives, swaps and structured products for permissibility under applicable regulations. She also advises on emerging fintech technologies, including on the structure and implications of various types of relationships between financial institutions and fintech companies. Ms. Harrington assists clients in strategic responses to investigations, congressional inquiries and testimony from a bank regulatory perspective. Additionally, she leads regulatory advocacy initiatives on behalf of clients and trade groups and provides strategic advice regarding policy responses on a wide range of US regulatory policy proposals with respect to US banking laws and regulations.

Professional Activities 

Ms. Harrington served as chair of the Practicing Law Institute’s 2019 Banking Law Institute and is currently vice chair of the Legislative and Regulatory Subcommittee of the American Bar Association’s Banking Law Committee. Ms. Harrington is a frequent speaker at industry conferences and will teach a class on financial law and regulation at Duke University School of Law during the 2020 spring semester.

Previous Experience

Prior to joining WilmerHale, Ms. Harrington was the US head of bank regulatory policy at Barclays. In this role, she led and managed the development of US bank regulatory policy priorities and strategy, including the development of comment letters, agency engagement and policy approaches to agency engagement. Ms. Harrington focused on the tailoring of the enhanced prudential standards including capital, liquidity, total loss absorbing capacity (TLAC) and stress testing standards, particularly with respect to foreign banking organizations (FBOs). Ms. Harrington also led the development of the bank’s policy approach to guidance, transparency and tailoring supervision for banking organizations. She also managed regulatory policy efforts related to implementation of securities and derivatives markets (including the swap margin rule), the Volcker rule, and single counterparty credit limits (SCCL). 

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. She was responsible for developing and implementing policy across a number of post-crisis Dodd-Frank Act rulemakings and advised exam staff, senior staff and the Board of Governors regarding policy for major initiatives. She was also a leading member of a number of interagency groups dedicated to developing and formulating policy related to various rulemakings, including the Volcker rule (the 2013 final rule and the 2018 proposal), the swap margin rules and the qualified financial contract (QFC stay rules). During her time at the board, Ms. Harrington focused on foreign bank regulation and activities of US banks operating abroad; control rules, including private equity investments in banks, de novo charters and the structure of noncontrolling investments; sections 23A and B of the Federal Reserve Act and the FRB’s Regulation W; derivatives regulation including the swap margin rule; securities financing transactions; enhanced prudential standards; total loss-absorbing capacity requirements (TLAC), single counterparty credit limits (SCCL), and the Volcker rule. Ms. Harrington also analyzed numerous proposals, applications and issues arising under US banking laws, including the Bank Holding Company Act, the Change in Bank Control Act, the Federal Reserve Act, the Bank Merger Act, and the International Banking Act and related regulations. 

Insights & News

Credentials

  • Education

    • JD, Boston College Law School, 2008

      magna cum laude Order of the Coif, Note Editor, Boston College Law Review
    • AB, Economics, Harvard College, 2002

      magna cum laude
  • Admissions

    • New York

* Admitted to practice only in New York. Supervised by members of the firm who are members of the District of Columbia bar.

Credentials

* Admitted to practice only in New York. Supervised by members of the firm who are members of the District of Columbia bar.