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Insurance Companies

Insurance companies engaged in federally regulated banking and housing activities

Insurance companies that participate in federally regulated banking and housing activities operate at the intersection of state insurance regulation and federal financial regulation. We advise insurance company clients on the federal banking, housing finance, and consumer protection rules that apply to those activities, including their obligations under federal supervisory frameworks. Our work spans regulatory advice, comment letters and legislative advocacy on federal proposals affecting the sector, and transaction support for activities that touch federally regulated functions.

Services we provide to insurance clients include:

Licensing & Transactions

Charter Options: We provide clients with strategic legal advice on charter, license, and operating model options, including charters for commercial banks, ILCs, national trust banks, and limited-purpose state banks, as well as money transmission and foreign bank licenses.
Due Diligence: We conduct regulatory due diligence on financial services acquisition and investment targets.
Product Advice: We assess new financial products and services, providing advice on regulatory requirements, licensing obligations, communication strategies, and product structure recommendations.
Regulatory Applications: We assist clients with applications related to specific initiatives and transactions, including applications for charters, conversions, acquisitions, and new activities.

Public Policy

Agency Challenges: We provide technical legal advice and strategic counsel to clients who are contemplating or pursuing challenges to agency actions.
Bill and Rule Analysis: We provide analysis of legislative proposals and regulatory rulemakings, as well as summaries and analysis of comments submitted by other stakeholders.
Comment Letters: We draft comment letters for clients on regulatory proposals and analyze the broader comment record to help clients understand where their position sits in the field.
Congressional Testimony: We prepare written and oral testimony for Congressional hearings on financial services law and regulation.
Executive Briefings: We prepare and deliver regulatory update briefings to client senior executives visiting Washington and help prepare them for meetings with regulators, congressional staff, and executive branch officials.
FOIA Requests: We submit Freedom of Information Act (FOIA) requests to federal agencies and follow up with demand letters to obtain regulatory documents and agency records.
Legislative Drafting: We draft bills, amendments, and legislative text to support clients' advocacy efforts relating to financial services regulation and policy.
Monitoring & Tracking: We perform tailored monitoring of regulatory developments and provide custom trackers, reports, and other data products.
Ongoing Advice: We provide ongoing regulatory advice through participation in regular conference calls and meetings, responding to questions as they arise during product development and operations.
White Papers: We produce policy white papers and analytical studies on financial services regulatory issues.

Regulation & Compliance

Consumer Compliance: We assist clients with compliance matters on a variety of federal banking and consumer financial services laws including TILA, RESPA, HMDA, FCRA, CRA, privacy, fair lending, compliance management, and UDAP/UDAAP.
Impact Analysis: We help clients understand the impact of existing and proposed laws and regulations on new or existing products and services.
Regulatory Inventory: We build and maintain comprehensive and special-purpose inventories of regulatory content and obligations.
Consumer Financial Protection Insurance Companies