Partner
Norton Rose Fulbright US LLP
Tom Delaney is a Partner based in Washington, DC. He advises international and domestic financial services firms including banks, branches of foreign banks savings associations, ILCs, FinTechs, insurance companies, payment providers and investment funds with respect to US and cross-border compliance obligations. He advises on a wide range of issues, including compliance with the Bank Holding Company Act, the National Bank Act, the Federal Deposit Insurance Act and the Bank Secrecy Act. His strategic advice enables clients to resolve regulatory, supervisory, and structural impediments to their corporate objectives.
Additionally, Tom oversees the conduct of internal investigations, advises on remediation measures and aggressively defends financial services firms that become the target of enforcement proceedings and Congressional investigations.
Recent Articles & Comments
The new guidance issued by the FRB aligns federal policy governing crypto-related activities of state member banks with those that have been approved recently for national banks by the OCC. Historically, activities in which state member banks can engage have been pegged to those permitted for national banks. Arguably the OCC’s approval earlier this month, permitting national banks to engage as riskless principal in crypto transactions, gave national banks an advantage over state member…
If there was any doubt, the OCC’s preliminary findings regarding information it has obtained in the aftermath of the issuance of Executive Order 14331, confirms that the OCC is serious about following through on President Trump’s initiative to guarantee fair banking for all Americans. Based on a review of nine of the largest national banks, the preliminary findings state that the OCC has observed that between 2020-2023, banks maintained, "public and nonpublic polices restricting certain…
The OCC’s decision to allow national banks to engage in riskless principal crypto asset transactions is another significant step among several taken lately by the national bank regulator toward integrating crypto assets into the traditional financial system. As reflected in the underlying interpretive letter, the OCC views this action as a logical outgrowth of established precedent in terms of riskless principal authority for national banks. The ability to engage in riskless principal…
The fact that this is a bipartisan bill is noteworthy in itself. The bill would increase deposit insurance coverage to checking and NOW account balances, which currently are covered together with other types of deposits, but only for such balances at non-SIFI domestic banks and credit unions. The $10 million balance threshold is much higher than the $250,000 insurance threshold provided to deposit accounts under current law. If enacted, this could lead businesses and wealthy individuals…