You are viewing a Web site, archived on 00:41:16 Oct 15, 2004. It is now a Federal record managed by the National Archives and Records Administration.
External links, forms, and search boxes may not function within this collection. Note that this document was downloaded, and not saved because it was a duplicate of a previously captured version (21:25:20 Oct 14, 2004). HTTP headers presented here are from the original capture.

Skip to quick links of this areaSkip to main contentOCC Logo Comptroller of the Currency, Administrator of national Banks

| | | | | |

Legal and Regulatory

Search this Site:

Search Tips

What's New
About the OCC
Banker Education
Careers at the OCC
Community Affairs
Corporate Applications
CRA Information
Consumer Complaints
and Assistance
Electronic Banking
Legal and Regulatory
  • News
  • Legal Careers
  • Enforcement Actions
  • Guidance, Precedents, Court Documents
  • Laws and Regulations
  • Beneficial Ownership Reporting
  • Papers & Speeches
  • Skip to main content
    News Releases
    Public Information
    Related Sites
    Treasury Homepage
    National BankNet for Chartered National Banks

    End of Left Navigation links group

    OCC Law Department

    The Office of the Comptroller of the Currency, established in 1863, is a bureau of the Treasury Department. The Comptroller of the Currency is appointed by the President and confirmed by the Senate for a term of five years. The Office's principal function is the supervision of the national banking system. A staff of over 1,800 bank examiners performs the statutorily required regular examinations of more than 2,100 banks subject to the Comptroller's supervision. The OCC is in the forefront of contemporary issues in the financial services industry, developing banking regulations and legislation to modernize banking law, and streamlining regulatory processes.

    The Law Department, which is managed centrally by the Chief Counsel's office, consists of seven legal practice areas located in the Washington headquarters office and general practice offices in each of the four district office locations.

    Law Department Organization Chart, click for a detailed description

    Chief Counsel’s Office

    Enforcement & Compliance

    Administrative & Internal Law

    Legislative & Regulatory Activities

    Bank Activities & Structure


    Community & Consumer Law

    Securities & Corporate Practices

    Northeastern District

    Central District

    Southern District

    Western District


    Chief Counsel’s Office

    (202) 874-5200



    The Chief Counsel's Office (CCO) centrally manages the Law Department. OCC attorneys:

    ·      Develop innovative, precedential opinions on contemporary issues (preemption, derivatives, new bank products, expanding bank markets, interstate banking, privacy, fair lending, community reinvestment and other consumer issues);

    ·      Enforce compliance with banking requirements by national banks through administrative actions;

    ·      Ensure protection and fair treatment of bank customers through application of consumer laws and regulations;

    ·      Develop banking regulations and legislation to modernize banking law;

    ·      Investigate federal securities law violations and enforce applicable securities laws;

    ·      Handle international banking issues and negotiate international agreements;

    ·      Represent the Comptroller in litigation involving any of OCC's operations.

    Julie L. Williams First Senior Deputy Comptroller and Chief Counsel

    Daniel Stipano

    Deputy Chief Counsel

    Raymond Natter

    Deputy Chief Counsel

    James Gillespie

    Assistant Chief Counsel

    Amy Friend

    Assistant Chief Counsel

    Administrative & Internal Law  (AIL)




    The Administrative and Internal Law Division (AIL) is responsible for providing legal advice relating to the OCC's operation as a federal agency: personnel (compensation and benefits, civil service, EEO); the ethics program; assessments; delegations; financial management; federal information law (including FOIA, Privacy Act, Right to Financial Privacy Act); and contracts and leasing.  AIL also administers the entry-level attorney recruitment program.


    David Kane


    Harold Hansen

    Assistant Director


    Bank Activities & Structure (BAS)




    The Bank Activities and Structure Division (BAS) provides advice on a broad range of banking law questions.  It advises on bank structure matters arising in the licensing context such as chartering national banks, branching, operating subsidiaries, financial subsidiaries, non-controlling investments in other entities, conversions, mergers and acquisitions, antitrust issues, interstate operations, change in control, and management interlocks. In addition, BAS advises on general bank powers and activities, electronic banking, bank-owned life insurance, real estate and leasing activities, lending limits, interest rate exportation, bank officer and director issues, affiliate insider transactions, and bank premises and trade names. 

    Finally, BAS advises on problem bank and resolution matters, voluntary liquidations, conservatorship, receivership, golden parachutes, and other banking law questions arising in a problem bank resolution context.  These questions involve interpretation of provisions of law applicable to national banks including the National Bank Act, Federal Deposit Insurance Act, FDIC Improvements Act, Bank Holding Company Act, Bank Merger Act, Change in Bank Control Act, Depository Institutions Management Interlocks Act, Riegle-Neal Interstate Banking and Branching Efficiency Act, Financial Institutions Reform, Recovery and Enforcement Act, Gramm-Leach-Bliley Act, and Sarbanes-Oxley Act.


    Eric Thompson


    William Glidden

    Assistant Director

    Kristina Whittaker

    Assistant Director

    Community and Consumer Law (CCL)




    The Community and Consumer Law Division (CCL) provides legal interpretations and advice on consumer protection, fair lending and community reinvestment issues.  The Division is also responsible for legal issues related to the bank community development powers and activities, including activities conducted within the bank, investments in community development corporations and projects, and participation in community development financial institutions.


    Michael Bylsma


    Stephen VanMeter

    Assistant Director

    Enforcement and Compliance (E&C) 202-874-4800



    The Enforcement and Compliance Division (E&C) is responsible for handling all non-delegated enforcement actions, including large civil money penalties, suspensions and removals, temporary cease and desist orders, and other administrative enforcement actions to assure compliance with federal banking laws by national banks and officials.

    The Division also acts as a liaison with the Department of Justice on significant referrals for criminal acts involving bank officials and works closely with the Department and the other bank regulatory agencies on coordination of law enforcement efforts involving insured financial institutions.

    Brian McCormally Director

    Robert Pasley

    Assistant Director

    Gerard Sexton

    Assistant Director

    Legislative & Regulatory Activities (LRA)



    The Legislative and Regulatory Activities division (LRA) is responsible for the following areas of the law department’s work:

    ·      Developing and drafting the OCC’s regulations and ensuring the agency's compliance with the various Federal statutes and executive orders that govern the rulemaking process;

    ·      Monitoring pending legislation of significance to national banks or the OCC and providing legal support for the agency’s legislative work;

    ·      Providing legal advice on international banking issues relating to foreign banks’ Federal branches or agencies in the United States and the foreign operations of national banks;

    ·      Providing legal advice and preparing legal opinions on the applicability of state laws to national banks; and

    ·      Providing legal advice on issues relating to national banks' regulatory capital requirements. 

    Karen Solomon Director

    Nancy Michaleski

    Assistant Director/Counsel for International Activities

    Stuart Feldstein

    Assistant Director

    Mark Tenhundfeld

    Assistant Director


    Litigation (LIT)




    The principal duties of the Litigation Division fall into six categories:

    Representing OCC in court

    Federal courts – in actions dealing with national bank powers and banking issues, OCC has the statutory right to represent itself (as opposed to relying on the Department of Justice) in all federal courts except the Supreme Court. Cases handled by the Litigation Division in federal courts include such varied subjects as national bank powers, preemption of state law, claims challenging OCC enforcement and bank resolution actions, and OCC decisions, orders and regulations.

    State courts – seldom if ever is OCC a party in state court.  Frequently, however, issues presented in state court touch upon OCC or other federal regulations, OCC interests, or important elements of national bank powers and operations. In such cases the Litigation Division often finds it necessary or helpful to file a brief or letter informing a state court of OCC’s position on some specific legal issue.

    Representing OCC in the administrative phase of personnel –EEO and MSPB– actions.

    Administering OCC’s regulation of 12 C.F.R. Part 4, subpart C, regarding confidential supervisory information.  This involves analyzing and responding to requests for such information, responding to subpoenas for such information, and informing courts of OCC’s regulation in cases where such information is sought to be obtained directly from a bank or other non-OCC party.

    In administrative enforcement actions brought by OCC’s Enforcement and Compliance Division, advising the Comptroller regarding administrative law judge decisions appealed to the Comptroller, and drafting the Comptroller’s decision document in such instances.

    Providing litigation risk advice, whenever requested, on all relevant topics including bank powers, preemption, enforcement and problem bank resolution, and personnel matters.

    Preparing the legal memoranda necessary for the preparation of problem bank resolutions .


    Horace Sneed Director

    Ford Barrett

    Assistant Director

    Rosa Koppel

    Assistant Director


    Securities & Corporate Practices Division (SCP)




    The Securities and Corporate Practices Division provides legal counsel to the OCC and advises banks and the public on a broad range of federal banking and securities law matters.  It provides advice on bank powers, securities activities, derivatives activities, complex structured finance transactions, securitization, capital markets activities, fiduciary matters, corporate governance, director and shareholder issues, corporate activities, functional regulation, annuities and insurance, debt cancellation contracts, the anti-tying provisions, and bank investments. 

    SCP provides counsel on corporate applications and notices, including those relating to operating subsidiaries and financial subsidiaries, and regulatory and legislative matters within its areas of expertise.  In connection with these activities, SCP addresses questions relating to the National Bank Act, Federal Deposit Insurance Act, FDIC Improvements Act, Bank Holding Company Act, Financial Institutions Recovery and Enforcement Act, Gramm-Leach-Bliley Act, and Sarbanes-Oxley Act.  SCP also administers and enforces the federal securities laws affecting national banks that: have securities registered under the Securities Exchange Act of 1934; offer their securities to the public; act as transfer agents; or act as municipal or government securities dealers. 

    The division also serves as liaison with the Securities and Exchange Commission, the National Association of Securities Dealers, and the Commodities Futures Trading Commission.


    Ellen Broadman Director

    William Dehnke

    Assistant Director

    Donald Lamson

    Assistant Director


    District Counsel Offices


    The District Counsel and their attorneys serve as the OCC’s frontline legal advisors, working directly with bank examiners in the field, assistant deputy comptrollers in Bank Supervision, district licensing staff, and the district deputy comptrollers. District attorneys also advise large and mid-size bank examination teams within the same geographic areas and deputy comptrollers for the large and mid-size banks.  They advise these clients on virtually the entire spectrum of banking law issues, frequently dealing with questions that arise during bank examinations and require prompt resolution. 

    District attorneys frequently provide advice to banking companies, bank counsel, and law firms on the most significant aspects of the national bank charter and how particular structures or transactions could be undertaken to solve operational, legal, or financial obstacles to the lawful exercise of the powers of a national bank or to better service customers in a particular market.  Further, the District Counsel are the OCC’s frontline legal representatives with respect to U.S. Attorneys’ Offices, state banking departments, and other local offices of federal and state agencies. 

    District attorneys provide legal support on all types of enforcement actions, including formal and informal agency actions against banks, individuals, and other institution-affiliated parties.  They also conduct legal training programs for examiners and represent the Law Department as speakers at external seminars for private sector attorneys and at district and large bank outreach meetings.  The District Counsel offices prepare a variety of significant enforcement actions, corporate opinions, and legal advisory letters.


    Northeastern District Office (NEDO)


    Jonathan Rushdoony District Counsel


    Southern District Office (SODO)


    Randy Ryskamp District Counsel


    Central District Office (CEDO)


    Coreen Arnold District Counsel


    Western District Office (WEDO)


    Lance Cantor District Counsel


    This page may contain PDF documents
    Download Adobe Acrobat Reader 5.0

    You are entering an official United States government system, which may be used only for authorized purposes. Unauthorized modification of any information stored on this system may result in criminal prosecution.