Overview
Lawrence D. Kaplan is Chair of the Bank Regulatory group in the Global Banking and Payments Systems practice and is based in the firm’s Washington, D.C. office. He advises clients on all aspects of bank regulatory issues, with an emphasis on corporate structuring, control, operations, compliance, problem banks, and enforcement.
Larry’s practice frequently involves the representation of traditional and nontraditional financial services holding companies and financial entities in transactions and matters before federal and state bank regulatory agencies, including merger and acquisition transactions, capital raising activities, joint ventures, de novo charters, and novel product offerings including cryptocurrency activities of banks. He has extensive experience advising clients on issues associated with the provision of financial services through technology and with consumer finance requirements.
Larry’s practice regularly involves advice to clients with respect to anti-money laundering and sanctions programs, as well as data security and privacy matters. In addition, he regularly advises clients with respect to various requirements imposed by the Dodd-Frank Wall Street Reform and Consumer Protection Act, including issues under the Volcker Rule, as well as proposed reforms to financial services laws. Representative experience includes:
- Citigroup on Citi Ventures’ Impact Fund in connection with addressing bank holding company and Volcker Rule compliance issues.
- Cross River Bank on regulatory issues, including with respect to its Fintech and payment relationships, including numerous regulatory filings under applicable digital asset guidance.
- Ceridian National Trust Company on its de novo application for a national trust bank launched in 2023, including numerous regulatory filings, meetings, and presentations, from pre-filing through establishment.
- Pathward, N.A. (fka MetaBank) on bank regulatory matters, Fintech relationships, brokered deposit issues, and implementation of government stimulus programs.
- GenuBank with its proposed conversion from a state to a national bank, including a digital asset strategy; prepared numerous regulatory filings and made presentations to regulators (withdrawn).
- PayPal/X.com in its initial establishment and retention of its money transmitter licenses and various regulatory issues.
- Figure Technologies on bank and state regulatory matters with respect to its product offerings.
- BitPay on its regulatory applications to form a cryptocurrency merchant acquiring bank, BitPay National Trust Bank (withdrawn).
Larry is an Adjunct Clinical Assistant Professor at the University of Michigan Law School and serves on the Board of Advisors for the Center for Banking and Finance at the University of North Carolina. He is a former director of Women in Housing Finance, in Washington, D.C.
Representations
- Citigroup on Citi Ventures’ Impact Fund in connection with addressing bank holding company and Volcker Rule compliance issues.
- Cross River Bank on regulatory issues, including with respect to its Fintech and payment relationships, including numerous regulatory filings under applicable digital asset guidance.
- Ceridian National Trust Company on its de novo application for a national trust bank launched in 2023, including numerous regulatory filings, meetings, and presentations, from pre-filing through establishment.
- Pathward, N.A. (fka MetaBank) on bank regulatory matters, Fintech relationships, brokered deposit issues, and implementation of government stimulus programs.
- GenuBank with its proposed conversion from a state to a national bank, including a digital asset strategy; prepared numerous regulatory filings and made presentations to regulators (withdrawn).
- PayPal/X.com in its initial establishment and retention of its money transmitter licenses and various regulatory issues.
- Figure Technologies on bank and state regulatory matters with respect to its product offerings.
- BitPay on its regulatory applications to form a cryptocurrency merchant acquiring bank, BitPay National Trust Bank (withdrawn).
news
insights
- FDIC Finalizes Brokered Deposits Rule Promoting Bank-Fintech Partnerships - December 21st, 2020
- CFPB FinTech Regulatory Innovation Initiatives Echo International Regimes - October 2nd, 2019
- Fed Consolidated Regulation Poses New Challenges for Savings and Loan Holding Companies - May 12th, 2011
- Regulators Propose Skin in the Game Rule - April 11th, 2011
Engagement & Publications
- Frequent source for major media publications and financial news programs on banking matters
- Frequent public speaker on bank regulatory developments
- Author of numerous articles on financial services issues
- Co-authored Chapter 31 to E-Commerce & Internet Law –2nd Edition (2009) — “Online Financial Transactions and Payment Mechanisms.”
Involvement
- Served as senior attorney in the Chief Counsel’s Office of the U.S. Department of Treasury’s Office of Thrift Supervision