Sara Lenet has experience in a wide variety of banking, corporate and securities law matters. She regularly advises federally and state-chartered financial institutions and their holding companies on bank regulatory matters, including permissible activities and investments, transactions with affiliates (Regulation W) and compliance with the Dodd-Frank Act and Volcker Rule. Sara also represents such entities in dealings with their federal and state regulators, including the Federal Deposit Insurance Corporation, Federal Reserve, Office of the Comptroller of the Currency, New York State Department of Financial Services, Georgia Department of Banking and Finance and others.
Sara also advises both financial institutions and companies in other industries on a broad range of corporate matters and transactions, including mergers and acquisitions.
- Counsel to banks headquartered in the New York area and the Southeast on bank regulatory matters.
- Counsel to buyers and sellers in domestic and international merger and acquisition transactions.
- Counsel to banks and bank holding companies regarding the development of Volcker Rule compliance programs and other Volcker Rule compliance.
- Counsel to multiple banks in connection with charter conversions.
On December 10, 2013, the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, the Securities and Exchange Commission and the Commodity Futures Trading Commission (the “Agencies”) each adopted a final rule (the “Final Rule”) implementing Section 619 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, commonly referred to as the “Volcker Rule.” The long-anticipated Final Rule was adopted over two years after the proposed rule was released, for which about 18,000 comment letters were received.
This advisory provides a high-level summary of the Final Rule only, and does not purport to be a complete explication of all of the details contained therein. The Final Rule is highly complex, reflecting 71 pages of rules and approximately 900 pages of supplemental materials (with over 2800 footnotes) from five different regulatory agencies, each of which has discretion to interpret the Final Rule. There will be numerous interpretive questions to be resolved by the Agencies in regulatory commentary, Q&A, bulletins, examination guidance and other releases going forward. Thus, banking entities engaged in, or wishing to engage in, activities potentially subject to the Final Rule should consult with their regular Alston & Bird lawyer or one of the lawyers listed at the end of this advisory to help assess particular concerns.
December 19, 2013
- CFA Institute’s Claritas® Investment Certificate