Clients look to our Financial Institutions practice for assistance with complex, challenging federal regulatory and legislative, litigation, enforcement, and business transaction matters that impact them as banks, card issuers, insurance companies, broker dealers, mortgage lenders, database operators, on-line firms and other financial services providers. We have extensive experience in particular areas including retail financial services, privacy and information security, international banking, and anti-money laundering matters. Our lawyers are at the forefront of complex issues that impact financial institutions and providers of financial services here and worldwide.

Many of our attorneys gained valuable expertise and insights serving in major roles at the Office of the Comptroller of the Currency, the Federal Reserve Board, the Treasury Department, the Federal Trade Commission, the Department of Justice, the Securities and Exchange Commission, the Department of Commerce, and the White House before joining the firm. The depth and experience of both the department as a whole and its individual lawyers have been acknowledged by a number of esteemed publications, including Chambers USA and the Wall Street Journal.


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Brown, Reginald J.

Reginald J. Brown

Chair, Financial Institutions Practice Group

+1 202 663 6430 (t)

Gutierrez, Franca Harris

Franca Harris Gutierrez

Vice Chair, Financial Institutions Practice Group

+1 202 663 6557 (t)


We help our clients achieve their business objectives efficiently and cost-effectively. Over the past 30 years, we have built a practice of extensive breadth and depth in regulatory, transactional, litigation and enforcement matters for banks and other financial institutions. In the past two years, we have:

  • Represented banking institutions and insurance companies in dozens of class action matters and other key litigations at all levels of the federal and state court systems. In the last two terms of the US Supreme Court, we won two cases involving retail banking activities for financial institution clients: Beneficial National Bank and Beneficial Tax Masters Inc. v. Anderson; and Pfennig v. Household Credit Services, Inc.
  • Handled two of the largest recent credit card portfolio transactions: (1) we represented Bank One in its acquisition of Circuit City's credit card portfolio and the related infrastructure for $1.8 billion, and (2) we represented another major issuer in the sale of a $1.5 billion tranche of a portfolio co-branded with a major electronics retailer
  • Assisted a major card issuer in the negotiation of a core dedication agreement with one of the major bankcard systems
  • Advised Citigroup in negotiating for acceptance of its Diners Club cards within the MasterCard system
  • Helped lead industry efforts that successfully shaped proposed amendments to the principal federal consumer lending regulations
  • Counseled financial institutions on sensitive compliance and internal investigation matters, on related dealings with regulators, and on the development of corporate compliance programs
  • Helped to shape anti-money laundering regulations and drafted anti-money laundering compliance programs for numerous banks, broker-dealers, and myriad other types of financial institutions
  • Represented clients in formal and informal enforcement actions brought by or before several agencies, including the Federal Reserve Board, the Comptroller of the Currency, the SEC, the Office of Federal Housing Enterprise Oversight and the Federal Trade Commission and assisted clients with anti-money laundering investigations.

Publications & News


October 1, 2015

Treasury Department Issues Comprehensive Assessment of US Money Laundering and Terrorist Financing Risk

An article by Franca Harris Gutierrez, Sharon Cohen Levin, Katrina Carroll, Elijah M. Alper, Andrew R. Golden and Jennifer R. Jacoby, published in the September 2015 edition of Market Solutions, Vol. 24, No. 3.

September 29, 2015

CFTC Updates Position Limits Rule

On September 22, 2015, the Commodity Futures Trading Commission (CFTC or Commission) unanimously approved the publication of a “supplemental” proposed rule on position limits. The supplemental proposal would modify the requirements in the proposed rules regarding the aggregation of positions subject to the Commission’s speculative position limits. Specifically, the proposal would modify the eligibility criteria and simplify the process for claiming an exemption from the aggregation requirements for owners of more than 50 percent of another entity.

September 25, 2015

WilmerHale's Investigations Practice Tops the List in Global Ranking

WilmerHale's investigations practice is named at the top of Global Investigations Review's inaugural listing of the 100 leading global investigations and compliance practices.

September 18, 2015

SEC Issues Cybersecurity Examination Risk Alert 

On September 15, the Securities and Exchange Commission’s (SEC) Office of Compliance Inspections and Examinations (OCIE) issued a Risk Alert re-emphasizing the careful scrutiny it will give to the data security practices of broker-dealers and investment advisers and describing areas of particular interest.

September 18, 2015

Wilmer Cutler Pickering Hale and Dorr LLP Named a Top-Tier Firm by The Legal 500 UK

In the 2015 edition of The Legal 500 UK, WilmerHale is named a top-tier firm for dispute resolution - international arbitration and crime, fraud and licensing - fraud: white-collar crime, and is recommended in six other practice areas.

September 17, 2015

Diversity Journal Recognizes Two Partners Among Women Worth Watching

Partners Elizabeth Mitchell and Heather Zachary have been named to Diversity Journal's annual list of Women Worth Watching, which recognizes professional women for their passion, potential and positive influence both inside and outside the workplace.

September 15, 2015

Second Circuit Allows Whistleblower Retaliation Protection Without Reporting to SEC

In a 2-1 decision in Berman v. Neo@Ogilvy LLC, the US Court of Appeals for the Second Circuit ruled that whistleblowers who report securities law violations internally but not to the US Securities and Exchange Commission are protected under the Dodd-Frank Act from employer retaliation.

September 3, 2015

FinCEN Proposes AML Requirements for Registered Investment Advisers

The Financial Crimes Enforcement Network (FinCEN) has proposed long-expected regulations that would extend anti-money laundering (AML) requirements to federally registered investment advisers (RIA).

July 27, 2015

A Bold New Regulatory Landscape for Research: SEC Approves FINRA Rules Addressing Conflicts of Interest for Equity and Debt Research

More than ten years after the Global Research Settlement and the adoption of NASD Rule 2711, the Securities and Exchange Commission has approved new FINRA rules addressing conflicts of interest for both equity and debt research analysts and research reports.

July 22, 2015

Department of Defense Issues Final Rule Expanding Military Lending Act to Credit Cards and Other Consumer Lending Products

On July 21, 2015, the U.S. Department of Defense announced the final rule amending the Military Lending Act’s implementing regulations.


  • Our Financial Institutions Group received nationwide rankings in Chambers USA: America's Leading Lawyers for Business in the Financial Services Regulation: Banking (Compliance) and Financial Services Regulation: Consumer Finance (Compliance & Litigation) categories. Clients stated: "It's a treat to work with them on anything; they're outstanding. One of the top financial services practices in the country." Partner Franca Harris Gutierrez is noted individually for her skill in banking and consumer finance compliance matters.
  • Chambers USA: America's Leading Lawyers for Business hailed our Financial Institutions Group with a nationwide ranking in 2014. Clients say, "they are the smartest, best people out there on financial services regulation matters," and laude them as "very smart, very knowledgeable and very client service-oriented. A pleasure to deal with." Partner Franca Harris Gutierrez are recognized individually as leaders in their respective practice areas.  
  • Partner Franca Harris Gutierrez was selected to the 2013 list of The Best Lawyers in America for their work in banking law.
  • In 2013, IFLR100: The Guide to the World's Leading Financial Law Firms, recognized WilmerHale as a top firm in their financial services regulatory category.
  • The Wall Street Journal lauds the "quiet, behind-the-scenes approach" of our group, which includes Chair Reginald Brown, former Special Assistant to President George W. Bush and White House Counsel liaison to the Treasury Department and independent financial services agencies; and Vice Chair Franca Harris Gutierrez.

Volcker Rule Resources

On December 10, 2013, the Federal Banking Agencies, together with the SEC and CFTC, adopted a Final Rule to implement Section 13 of the Bank Holding Company Act (the Volcker Rule), which was added by Section 619 of the Dodd-Frank Act.

Our Securities and Financial Institutions teams have compiled for you these relevant resources to help reinforce your understanding of the Volcker Rule.

WilmerHale Publications and Presentations

Statutory and Rule Text

Agency Statements

Federal Reserve Statements on the Volcker Rule, December 10, 2013

FDIC Statements on the Volcker Rule, December 10, 2013

OCC Statement on the Volcker Rule, December 10, 2013

SEC Statements on the Volcker Rule, December 10, 2103

CFTC Statements on the Volcker Rule, December 10, 2103