Max represents U.S. and non-U.S. financial institutions, their non-bank affiliates, vendors, and other financial services providers on U.S. financial laws and core bank regulatory issues, involving the Federal Reserve, the Office of the Comptroller of the Currency (OCC), the Federal Deposit Insurance Corporation (FDIC), the Financial Crimes Enforcement Network (FinCEN), the Office of Foreign Assets Control (OFAC), the Consumer Financial Protection Bureau (CFPB), and state banking regulators.
He counsels clients on issues involving powers and permissible activities, structure and control, charter choice and conversions, Volcker Rule compliance, branching, affiliate transactions, third-party relationships, crypto and digital assets, bank-fintech partnerships and vendor issues, FDIC deposit insurance applications and coverage issues, FDIC recordkeeping requirements, passthrough insurance, and advertising rules.
Max also advises and manages regulatory applications for de novo institutions and activities, bank holding companies, business combinations, controlling and non-controlling equity investments, charter conversions, U.S. entry options for non‑U.S. financial institutions, including the establishment of U.S. branches and representative offices, and licensing and compliance considerations for fintechs and technology companies, bank partners, and non-bank financial services providers.
Prior to private practice, Max worked at the Federal Deposit Insurance Corporation.
Max also serves as general counsel to Women in Housing and Finance, a premier, nonpartisan association of women and men that actively promotes its members in the fields of housing and financial services while retaining a focus on its female members.
Related Practices
- Applications for New Charters, Deposit Insurance, and Other Regulator Consents
- Banking and Financial Services Regulatory
- Due Diligence
- Financial Services Investigations and Enforcement
- International
- Regulatory
- Regulation of Banks, Savings Associations, and Bank, Thrift and Financial Holding Companies
- Resolution of Depository Institutions
- US Supervision of International and Foreign Banking
Related Industries
Experience
Representative Matters
- Advising on and managing regulatory applications and other filings for financial institutions, their holding companies, and affiliates
- Conducting control analyses under the Federal Reserve’s control and controlling influence framework
- Assisting non-U.S. banks with U.S. entry, including the establishment of U.S. branches and advising on options for fintechs and other nonbank financial services providers
- Responding to civil investigative demands and other investigations, handling matters involving confidential supervisory information, and conducting internal investigations and voluntary self-disclosures to bank regulators, the CFPB and OFAC
- Conducting deal due diligences with respect to financial regulatory issues, including control issues, and BSA/AML requirements
- Advising on the remediation of supervisory issues and drafting and revising policies and procedures
- Advising on appeals of supervisory ratings and findings
- Conducting institution-wide compliance inventories in connection with remediation of supervisory concerns
- Advising on supervisory expectations and contract requirements concerning vendor management issues
- Advising litigation teams on bank regulatory and supervisory expectations
- Counseling banking organizations on cross-border questions involving U.S. regulatory obligations and supervisory standards in conjunction with those of various non-U.S. counterparts
- Analyzing digital assets under applicable state and federal laws
Insights
Credentials
Education
- J.D. George Washington University Law School 2014
- B.A. International Affairs summa cum laude George Washington University 2007
Bar Admissions
- District of Columbia
- New York
Professional Memberships and Activities
- Co-vice chair, Subcommittee on Enforcement, American Bar Association’s Banking Law Committee
- General counsel, Women in Housing and Finance