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Experience
Scott Anenberg’s practice focuses on banking and financial services. He has over 25 years of experience representing global and domestic commercial banks, thrifts, and other financial services companies, as well as their holding companies and affiliates, on a wide variety of strategic, regulatory, compliance, and enforcement issues before federal and state agencies.
He regularly advises banking and financial services clients on legislative and regulatory developments; geographic and product expansion; acquisitions and reorganizations; anti-money laundering, USA PATRIOT Act and Bank Secrecy Act compliance; preemption; privacy; transactions with affiliates; regulatory capital; consumer compliance; and electronic banking and commerce.
Earlier in his career, Scott worked for the Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency. He is also active in the firm’s Israel-related practice.
Notable Engagements
- Represented the sellers in the seventh largest US bank merger announced in 2008.
- Represented a foreign bank in several transactions designed to rationalize and consolidate its US operations, including precedent-setting transfers of its FDIC-insured branches to its US bank subsidiary made possible by first obtaining an innovative ruling from the FDIC under the Riegle-Neal Interstate Banking Act.
- Helped a federal savings bank in establishing the first-of-its-kind REIT subsidiary as a vehicle to issue tax-advantaged Tier 1 capital.
- Represented a foreign bank in US matters relating to its privatization and subsequent sale of its New York bank subsidiary.
- Advised the US subsidiary of a foreign bank in its acquisition from the FDIC of a failed Florida bank, culminating in a strategy designed to enable the bank to better serve its customer base and pursue new business opportunities in Florida despite that state’s restrictive interstate banking laws.
- Represented a large insurance company in various regulatory and enforcement matters relating to its ownership of a thrift.
- Assisted several banks with reviews, internal investigations and potential enforcement actions related to anti-money laundering issues.
- Helped several foreign banks apply to establish branches, representative offices and agencies in the US.
- Helped a major financial services trade group obtain amendments to various aspects of the FDIC’s regulations governing US branches of foreign banks.
- Represented domestic and foreign banking clients in establishing securities brokerage subsidiaries in order to comply with the “push-out” provisions of the Gramm-Leach-Bliley Act.
- Obtained the first official interpretation involving the application of FDIC deposit insurance rules to electronic banking products.
Education
The George Washington University Law School, JD, with high honors, 1978 • Washington University, BA, magna cum laude, 1975; Order of the Coif
Admitted
- District of Columbia, 1978
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