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 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


November 24, 2015

Four Things Companies Should Know About the SEC’s 2015 Whistleblower Report

The SEC recently published data showing significant increases in tips received under its Dodd-Frank Whistleblower Program. Released on November 16, the 2015 annual report also provided important guidance to companies on the SEC’s whistleblower-related priorities through fiscal year 2016.

November 13, 2015

Second Circuit Clarifies Common Legal Interest and Work Product Doctrines for Material Shared Among Transacting Parties

The U.S. Court of Appeals for the Second Circuit recently ruled that the “common interest” doctrine protects legal and tax liability analysis prepared for a client and subsequently shared with a consortium of banks providing financing for the client.

November 9, 2015

FTC Joins With Federal, State and Local Authorities on Nationwide Debt Collection Enforcement Initiative

On November 4, 2015, a group of law enforcement authorities, led by the Federal Trade Commission, announced Operation Collection Protection, a coordinated federal, state and local initiative aimed at illegal debt collection practices.

November 2, 2015

WilmerHale Receives Top Rankings, Named “Law Firm of the Year” in Mutual Funds Law in 2016 U.S. News - Best Lawyers® “Best Law Firms” List

U.S. News - Best Lawyers® has named WilmerHale "Law Firm of the Year" in Mutual Funds Law and recognizes the firm as a first-tier law firm in 21 national and 58 metro-area rankings. In addition, the firm boasts more than 30 second- and third-tier rankings.

October 27, 2015

Partner Sharon Levin Receives Prestigious Attorney General’s Award for Distinguished Service

Sharon Cohen Levin and a multi-agency team received the 2015 Attorney General’s Award for Distinguished Service—one of the highest accolades a legal team or individual can receive by the Department of Justice. Attorney General Loretta E. Lynch presented the award to Levin and the team at the 63rd Annual Attorney General’s Awards Ceremony.

October 26, 2015

FinCEN Proposes AML Requirements for Registered Investment Advisers

An article by Franca Harris Gutierrez, Sharon Cohen Levin, Matthew A. Chambers, Timothy F. Silva, Katrina Carroll, Elijah M. Alper, and Carleton Goss, published in the October 2015 edition of Banking & Financial Services Policy Report, Vol. 34, No. 10.

October 26, 2015

Military Lending Act Poses Challenges and Risks for Lenders

An article by Daniel T. Chaudoin, Bradford Hardin Jr. and Gideon Hart, published in the October 2015 edition of Banking & Financial Services Policy Report, Vol. 34, No. 10.

October 22, 2015

CFPB Issues Final Rule to Improve Information About Access to Credit in the Mortgage Market

On October 15, 2015, the Consumer Financial Protection Bureau issued a final rule to implement amendments to the Home Mortgage Disclosure Act made by the Dodd-Frank Wall Street Reform and Consumer Protection Act.

October 8, 2015

CFPB Releases Outline of Proposals to Block Pre-Dispute Arbitration Agreements in Class Litigation

On October 7, 2015, the Consumer Financial Protection Bureau released an outline of proposals under consideration to ban class action waivers in contracts for consumer financial products and services.

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.


  • 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