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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bank, including a digital asset strategy; prepared numerous regulatory filings and made presentations to regulators (withdrawn).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).

    insights

    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

    Practice Areas

    Investment Management

    Corporate

    Financial Services

    Bank Regulatory

    Fintech and Payments

    ESG & Impact

    ESG & Sustainable Finance

    Impact Investing

    Consumer Financial Services


    Languages

    English


    Admissions

    District of Columbia Bar

    Pennsylvania Bar


    Education

    The George Washington University Law School, J.D. 1987

    University of Michigan, Ann Arbor, A.B. 1984