John C. Dugan, formerly Comptroller of the Currency from 2005-10, is a partner in the firm’s Washington, DC office and chairs the firm’s Financial Institutions Group. He advises clients on a range of legal matters affected by significantly increased regulatory requirements resulting from the financial crisis, including:
- implementation of the Dodd-Frank Act;
- financial institution mergers, acquisitions, and investments;
- litigation and enforcement issues;
- international financial regulation; and
- legislative and government relations issues.
As Comptroller, Mr. Dugan headed the agency that supervises over 1,500 national banks and federal branches of foreign banks, which together hold nearly two-thirds of the assets of the US commercial banking system. He also served on the Board of Directors of the Federal Deposit Insurance Corporation. During his five-year term, Mr. Dugan led the Office of the Comptroller of the Currency (OCC) through the financial crisis and ensuing recession that resulted in extraordinary regulatory and supervisory actions for national banks of all sizes, including government assistance provided under the Troubled Asset Relief Program (TARP); resolutions of large, mid-size, and community banks; and the successful implementation of regulatory “stress tests.”
Mr. Dugan also was deeply involved in numerous supervisory and regulatory initiatives, such as capital standards issued by the Basel Committee on Banking Supervision, on which he served; policy and regulatory recommendations of the Financial Stability Board, where he participated because of his chairmanship of the Joint Forum (an international committee of banking, securities, and insurance regulators); guidance and supervisory action on a range of residential mortgage and credit card issues; and successful litigation efforts to preserve key federal preemption attributes of the national bank charter.
Most recently, he directed the OCC’s efforts to help shape critical parts of the sweeping Dodd-Frank financial reform legislation, including its provisions on systemic risk regulation and the Financial Stability Oversight Council; federal preemption; new capital regulation; the Consumer Financial Protection Bureau; revamped derivatives regulation; and the so-called “Volcker Rule” limitations on banks’ trading and investment activities.
Before serving as Comptroller, Mr. Dugan was a partner in the firm, specializing in financial institution regulatory matters from 1993-2005. He had previously served at the U.S. Department of the Treasury from 1989 to 1993, where he was appointed Assistant Secretary for Domestic Finance and had extensive responsibility for policy initiatives involving banks and financial institutions, including the savings and loan cleanup, Glass-Steagall and banking reform, and regulation of government-sponsored enterprises. From 1985 to 1989, Mr. Dugan was Counsel and Minority General Counsel for the U.S. Senate Committee on Banking, Housing, and Urban Affairs, an active period during which the Committee passed the Competitive Equality Banking Act of 1987; the Proxmire Financial Modernization Act of 1988; and the Financial Institutions Reform, Recovery, and Enforcement Act of 1989.
Honors and Rankings
- International Financial Law Review: Americas Awards, Contribution to Regulatory Reform Award for his “invaluable input into post-crisis reforms” (2015)
- Legal 500, Financial Services: Litigation and Regulatory (2014)
- Chambers Global, Banking & Finance (2013-2015)
- Chambers USA - America's Leading Business Lawyers, Financial Services Regulation: Banking (Compliance) (2012-2014)
- Best Lawyers in America, Banking and Finance; Financial Services Regulation (2013-2015)
- The Best Lawyers in America, Washington Banking and Finance Lawyer of the Year (2013)
- Washington DC Super Lawyers, Banking (2013-2014)
- Washingtonian, Financial Services "Top Lawyer" (2013)
Publications and Speeches