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
While focusing on the impact the Basel III Endgame Proposal will have on the derivatives markets, Commissioner Mersinger’s comments align with the growing chorus of opposition to the proposed rule that has been expressed by leading banking trade groups and members of Congress.
ILCs are attractive options for companies, including non-banking companies, that want to offer financial services but not be subject at the parent company level to regulation as bank holding companies. The Dodd-Frank Act extended a regulatory moratorium that had applied to the approval of ILC charters since 2006. The statutory moratorium has expired, and in December 2020, the FDIC implemented a final rule that specified conditions for the approval of FDIC insurance (and certain other)…