Freedom of Information & Open Government

A recent — and somewhat frustrating — experience with a FOIA request prompted us to take a closer look at how the Act is being implemented. As background, FOIA was enacted in 1966 to provide transparency into governmental actions and to promote accountability for those actions. The Act has been amended several times in the past 30 years, most recently in 2016. The FOIA Improvement Act of 2016, which was passed by Congress, codified a "presumption of openness." As amended, FOIA now provides that an agency may withhold information in response to a FOIA request only if it reasonably foresees...

We provide comprehensive legal and regulatory support for government relations teams, trade associations, and policy consultants engaged in federal financial services policy advocacy. Our public policy practice covers the full range of advocacy support services, including congressional testimony, legislative drafting, comment letters, regulatory monitoring, FOIA requests, white papers, and strategic engagement with policymakers. We help clients understand regulatory developments, develop informed policy positions, and advocate effectively before Congress and federal agencies. Services...

Jim Sivon specializes in financial services law. He primarily works with financial institutions, fintechs, financial trade associations and consulting firms. Jim provides clients with strategic legal advice on charter options, including commercial bank charters, industrial loan company (ILC) charters, national trust bank charters, narrow state charters, money transmission licenses and options for foreign banks; prepares and shepherds regulatory applications related to corporate transactions and product approvals, including charter applications, Change in Bank Control filings, Bank Holding...

Mitch Plave specializes in financial services regulation and administrative law. Mitch previously served as Special Counsel for the Office of the Comptroller of the Currency (OCC) for over 27 years. At the OCC, he led the administrative law practice and played a key role in implementing significant cases and executive orders relating to rulemaking and the issuance of agency guidance. In connection with his leadership on administrative law and procedure, he represented the OCC at the Administrative Conference of the United States. Mitch was also the lead counsel on matters relating to the...