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, online firms and other financial services providers. We have extensive experience in 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 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 20, 2016

Banking Regulators Release Advanced Notice of Proposed Rulemaking on Enhanced Cyber Risk Management Standards

The agencies are considering establishing two tiers of enhanced standards—basic enhanced standards for all covered firms and even more stringent enhanced standards for systems that are "sector-critical."

October 14, 2016

D.C. Circuit Delivers a Major Setback to the CFPB

On October 11, the D.C. Circuit issued a major decision holding the structure of the Consumer Financial Protection Bureau (CFPB) unconstitutional and sharply limiting the CFPB's enforcement powers.

October 12, 2016

District Court Judge Rejects CFTC Manipulative Intent Standard

On September 30, 2016, Judge Analisa Torres of the Southern District of New York issued an order resolving competing motions for summary judgment in the Commodity Futures Trading Commission's ongoing action against Donald R. Wilson and his firm, DRW Investments LLC, for allegedly manipulating and attempting to manipulate the settlement price of certain interest rate futures contracts.

September 29, 2016

Brexit and Data Protection: The Impact on GDPR Compliance

As we wait for the UK to decide what arrangement it will seek with the European Union when it leaves, it may be useful to focus on what Brexit may mean for data protection.

September 15, 2016

New York Law Journal Selects Sharon Cohen Levin as a Top Women in Law

Levin joins 29 other lawyers who were chosen to the New York Law Journal's first Top Women in Law list. 

September 12, 2016

Federal Civil Penalties Set to Increase Significantly, Many Present Retroactivity Concerns

Matthew Martens, Reg Brown and Daniel Kearney discuss rules adopted by many federal agencies that significantly increase the maximum civil monetary penalties they can potentially impose in this article published by the Harvard Law School Forum on Corporate Governance and Financial Regulation.

September 9, 2016

Scope of the Jury Trial in Civil FIRREA Actions

In this article published by Law360, Matthew Martens, Sharon Cohen Levin and Reginald Brown detail the scope of the jury trial right in civil Financial Institutions Reform, Recovery and Enforcement Act actions.

August 10, 2016

Civil Penalties Set to Increase Significantly, Many Present Retroactivity Concerns

Over the past several months, many federal agencies have adopted rules significantly increasing the maximum civil monetary penalties (CMPs) they can potentially impose. The increased penalty amounts were adopted in response to recent legislation from Congress requiring that federal agencies make adjustments to “catch up” with inflation.

August 5, 2016

Department of Commerce Now Accepting Privacy Shield Self-Certifications: A Primer for Compliance and Self-Certification

The Privacy Shield framework is a voluntary program that provides companies with a mechanism for complying with EU data protection requirements when transferring personal data from the EU to the US. The framework is open to businesses subject to the enforcement jurisdiction of the US Federal Trade Commission or the US Department of Transportation.

July 21, 2016

NYDFS Issues Final Rule Requiring Certification of Compliance With AML Transaction Monitoring and Filtering Program Requirements 

The New York Department of Financial Services recently finalized a regulation that mandates detailed elements of the anti-money laundering transaction monitoring and sanctions filtering programs of covered institutions. The rule, published on June 30, 2016, also requires directors or senior officers to certify their institutions' compliance with these new standards.


  • 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