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
“If you didn’t mean it, it must not have happened.”
For several years, national banks, particularly smaller community banks, have bristled when confronted with critical OCC examination findings alleging discriminatory lending practices based on disparate-impact analyses. Banks subject to such examination criticism often pointed to the absence of any evidence indicating that they engaged in disparate treatment, intentional discrimination, based on the race, color or national origin of…
The actions taken by the Treasury indicate that only foreign reporting companies—an as yet undefined term—will be required to file beneficial owner information as contemplated by the CTA.
Despite the original intent of the CTA, beneficial owners of US formed LLCs will no longer be required to file information with FinCEN. It remains unclear what will happen with information that has already been filed with FinCEN by beneficial owners of US companies. Also, it will be…
This year, as compared to the adverse scenarios described for 2024, the unemployment shock rate is set at 10%, the same as the 2025 scenario. There is a slight difference in the starting unemployment rate reflecting the improvement in the level of unemployment that occurred in 2024. Perhaps this demonstrates that there can be business as usual, despite the turbulence being experienced by Federal Departmental agencies, at least for independent agencies such as the Federal Reserve.
Well before either of President Trump's elections, there were discussions at high policy levels about the need to streamline the Federal bank regulatory apparatus; potentially combining the agencies under the Treasury Department. Past proposals on regulatory consolidation have been met with strong objections by Fed staff (often accompanied by colleagues at the FDIC). Despite the furor over turf, arguments for independence around the levers of monetary policy are sound.
That…