Christopher M. Paridon

Chris routinely advises on bank mergers and acquisitions (M&A)—both strategic acquisitions and minority investments—and capital markets transactions involving financial institutions. He also handles supervisory questions and governance and compliance matters.

Chris advises clients regarding all manner of bank and financial regulatory matters, such as compliance and other questions under the Bank Holding Company Act (including the Volcker Rule), National Bank Act, Change in Bank Control Act, Federal Reserve Act, International Banking Act, Home Owners’ Loan Act, and Federal Deposit Insurance Act. He provides advice regarding most Federal Reserve regulations (including, among others, Reg D, Reg H, Reg K, Reg L, Reg O, Reg Q, Reg W, Reg Y, Reg BB, Reg LL, Reg MM, Reg VV, and Reg YY) and the rules and regulations of the Office of the Comptroller of the Currency (OCC) and Federal Deposit Insurance Corporation (FDIC).

Clients benefit from Chris’s deep knowledge of the financial regulatory landscape and his experience in the government, including in the Legal Division of the Board of Governors of the Federal Reserve System. At the Federal Reserve, Chris concentrated on the prudential regulation of banks and bank holding companies, including the implementation of the Volcker Rule and other provisions of the Dodd-Frank Act. He advised on M&A involving banks, bank holding companies, and nonbanking subsidiaries. Chris also assisted in the review of questions involving private equity investments in banks and bank holding companies, as well as restrictions on inter-affiliate transactions within organizations.

Regulatory, Compliance, and Related Corporate Matters

• All types of financial institutions on compliance with the Bank Holding Company Act, including the Volcker Rule, as well as the National Bank Act, Change in Bank Control Act, Federal Reserve Act, International Banking Act, Home Owners’ Loan Act, Federal Deposit Insurance Act, and other statutes and regulations applicable to banking organizations
• All types of banks, bank holding companies, savings and loan holding companies, and nonbank financial entities before the Federal Reserve, OCC, FDIC, New York Department of Financial Services, and other federal and state financial regulatory agencies
• Several large US banking organizations regarding their multibillion–dollar transformative acquisitions of fiduciary, advisory, and wealth management businesses, as well as other banking organizations regarding their options to divest control of existing interests in banking and financial businesses
• A large non-US bank on its emergency acquisition of another large non-US bank
• A US financial services firm regarding its re-banking by converting its trust company into a federal savings bank, as well as regarding its acquisition and conformance of the Europe, the Middle East and Africa (EMEA) asset management operations of a non-US bank
• A non-US bank on drafting and revising its compliance and investment policies related to the BHC Act, Volcker Rule, Reg W, and other US banking regulations
• Many US and non-US banking entities, including most global systemically important banks (G-SIBs) and super-regional/regional and other large banking organizations, regarding the establishment and implementation of their Volcker compliance policies and procedures, as well as ongoing compliance and interpretive questions
• Several US banking entities with respect to their advocacy and related matters in front of the Federal Reserve and other Volcker Rule agencies regarding the scope of entities captured by the definition of covered fund
• Several insured depository institutions in the review and drafting of deposit sweep and deposit account agreements for brokered deposit, disclosure, and other regulatory considerations
• A US G-SIB on its efforts to conform its recently acquired asset management operations to the requirements of the BHC Act, including options to de-control investment funds
• A non-US banking organization in its successful election to be treated as a financial holding company
• A non-US asset manager on its acquisition of a non-US bank and the associated deregistration of that non-US bank’s US branch
• A non-US bank on the sale of its wealth management business to a non-US G-SIB, including options to help the wealth management business conform to new regulatory requirements as a result of the transaction
• A US G-SIB on the sale of its majority stake in a US asset management business to the management team
• A non-US banking organization on its exemption request under the Federal Reserve’s Reg YY to hold certain portions of its asset management business outside of its intermediate holding company

Investment Management

• US and non-US banking organizations on their involvement with investment fund structures, including both proprietary and third-party funds as well as underlying fund investments
• US and non-US banking organizations regarding permissibility and other considerations for controlling and noncontrolling investments in banking, nonbanking, and other financial companies, as well as commercial and industrial companies
• Several banking organizations on bank regulatory considerations associated with their minority investments in and partnerships with digital banking companies, digital asset trading platforms, and other fintech operations
• A large US banking organization regarding the proposed divestiture of its subsidiary insured depository institution to private equity funds
• Multiple US banking organizations on their public welfare investments (both for purposes of the Community Reinvestment Act (CRA) and the Volcker Rule), including investments in funds that were designed to invest a majority of assets in CRA-eligible loans and assets; an investment in a fund designed to invest in renewable energy projects that were themselves CRA eligible; a noncontrolling investment in a minority-owned digital banking platform that was designed to benefit the local Black and Latino communities where it operates; and investments in private funds designed to qualify as public welfare funds under the Volcker Rule

Dodd Frank Act and Advocacy

• Many US and non-US financial institutions, including many of the largest domestic and international banks and regional banks, on the impact and implementation of the Dodd-Frank Act, the 2018 Financial Reform Act, and other financial services legislation
• Several US G-SIBs on various aspects of their resolution plans required under Section 165(d) of the Dodd-Frank Act
• A major US trade association on its comment letter related to rules implementing the proprietary trading and covered fund provisions of the Volcker Rule