John Cooney
PEOPLE

John Cooney

Of Counsel
cooney.john@dorsey.com

Overview

John is a financial services regulatory attorney and former bank general counsel. He advises banks, financial holding companies, and other financial services companies on regulatory compliance, supervisory matters, enforcement, and corporate governance.

He represents clients before the Office of the Comptroller of the Currency (OCC), Federal Reserve, Federal Deposit Insurance Corporation (FDIC), Consumer Financial Protection Bureau (CFPB), and state banking departments. His practice covers a broad range of banking regulation and compliance matters, including prudential regulatory requirements, deposit and payment systems, credit products, fair lending, Bank Secrecy Act and anti-money laundering (BSA/AML) compliance, sanctions, and Gramm-Leach-Bliley Act (GLBA) privacy and data security.

Before re-entering private practice, John served as general counsel at Ally Bank and MidWestOne Bank and senior regulatory counsel at Citizens Bank and USAA. That in-house experience gives him a firsthand understanding of the regulatory and business pressures his clients face every day. 

Education & Admissions

University of California, Berkeley, School of Law (J.D., 1985)

University of California, Berkeley, Goldman School of Public Policy (M.P.P., 1985)

University of Notre Dame (B.A., 1980)

Admissions

  • Minnesota
  • U.S. Court of Appeals for the Third Circuit
  • U.S. District Court for District of Minnesota

Clerkships

  • U.S. Court of Appeals for the Third Circuit, Honorable Collins J. Seitz, 1985-1986

Experience

Representative Work

  • Represents financial services companies before state and federal financial regulatory agencies. *
    • Ally Financial Inc. and Ally Bank. Legal liaison to Federal Reserve, FDIC and CFPB
    • US Bancorp and US Bank (f/k/a First Bank System and various First Banks). Provided advice on bank M&A transactions and drafted and processed state and federal bank acquisition and branching applications (MN, ND, SD, WA, IA, CO & OR); worked on and drafted proposed interstate banking legislation (ND & IA)
    • Chartered national bank for major Portuguese banking organization (NJ)
    • Section 20 application with the Federal Reserve
  • Advises executive leaders and Boards of Directors on banking regulation and compliance, including revised prudential regulatory requirements, new products and services, lending limits, investment securities, the Community Reinvestment Act, anti-tying laws, affiliate transactions, resolution plans (living wills), and GLBA privacy requirements. *
    • Ally Bank. Provided advice on these topics at Board meetings and in other settings; drafted legal sections of living wills and commented on and organized other sections of them
    • MidWestOne Bank. Provided advice on these topics at Board meetings and in other settings
  • Participates in the preparation for, and the conduct of, the examination and supervision of financial services companies by state and federal banking agencies. *
    • MidWestOne Bank. Helped prepare for and provided advice on legal/regulatory issues arising in FDIC and IA bank examinations
  • Provides advice on legislative and regulatory developments affecting financial services companies, including rules and supervisory guidance arising under Dodd-Frank Wall Street Reform, the Consumer Protection Act, the National Bank Act, the Gramm-Leach-Bliley Act, the Bank Holding Company Act, and similar statutes and regulations. *
    • MidWestOne Bank. Provided advice on these legislative/regulatory issues
    • US Bancorp and US Bank (First Bank System and various First Banks). Provided advice on these legislative/regulatory issues
    • ACT, Inc. Provided advice on education and EdTech legal/regulatory issues
  • Provides legal services associated with the organization, licensing, and operation of insured institutions, as well as holding companies, subsidiaries, and affiliates. *
    • Chartered national bank for major Portuguese banking organization (NJ)
    • MidWestOne Bank. Provided advice on different structures for establishing a state or national trust company to facilitate interstate activity
  • Established the legal infrastructure required to transform a large state-licensed auto lender into a financial holding company. *
    • Ally Financial Inc. Partnered with Chief Compliance Officer to establish the legal/regulatory infrastructure required for a bank/financial holding company
  • Provided critical legal support in connection with the negotiation and resolution of auto loan pricing compliance plan and worked with the CFPB and the settlement administrator with respect to the distribution of the $80 million settlement. *
    • Ally Financial Inc. Reviewed proposed consent orders; participated in meetings with the Federal Reserve, FDIC and CFPB to negotiate final consent orders
  • Provided legal support and advice during the negotiation of the 2011 Federal Reserve and FDIC mortgage-servicing consent orders. *
    • Ally Financial Inc. Reviewed proposed consent orders; participated in meetings with the CFPB to negotiate final consent orders
  • Drove the legal and regulatory strategy associated with material “bet-the-company” litigation, including two purported class actions alleging ADA/Unruh Act violations and TCPA violations, respectively. *
    • ACT, Inc.
*Experience occurred prior to re-joining Dorsey.

Industries & Practices

Banking & Financial Institutions
Financial Services Regulatory
Consumer Financial Services
Corporate Trust Services
Foreign Banks and Financial Institutions

Foreign Banks and Financial Institutions

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Bankruptcy & Financial Restructuring
Privacy & Social Media
Government Enforcement & Corporate Investigations

Government Enforcement & Corporate Investigations

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Securities & Financial Services Litigation & Enforcement

Securities & Financial Services Litigation & Enforcement

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  • Banking & Financial Institutions
  • Bankruptcy & Financial Restructuring
  • Consumer Financial Services
  • Corporate Trust Services
  • Financial Services Regulatory
  • FinTech
  • Foreign Banks and Financial Institutions
  • Government Enforcement & Corporate Investigations
  • Mortgage Banking
  • Privacy & Social Media
  • Securities & Financial Services Litigation & Enforcement
John Cooney