Derek M. Bush’s practice focuses on advising U.S. and international financial institutions and foreign sovereigns regarding the complete spectrum of U.S. bank regulatory matters and legislation. 

Among other areas, this includes regulatory requirements imposed under the Dodd-Frank Act, restructurings, corporate governance and investments by and in banking organizations; corporate transactions, including mergers and acquisitions, asset sales, privatizations, capital markets transactions, joint ventures and strategic alliances; and internal investigations and in enforcement proceedings involving the U.S. federal banking agencies.

He represents clients before the Federal Reserve Board, Federal Reserve Banks, the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation and the New York Department of Financial Services.

Derek joined the firm in 1995 and became a partner in 2003. 

Notable Experience

Regulatory Highlights

  • Several U.S. and non-U.S. banks on the preparation of resolution plans.

  • The Institute of International Bankers regarding various matters related to U.S. regulatory reform as applied to internationally headquartered institutions, including in connection with the Volcker Rule.

  • Numerous U.S. and non-U.S. banking organizations in all aspects of implementation of, and compliance with, the Volcker Rule.

  • Multiple U.S. and non-U.S. financial institutions, (including BNP Paribas, Barclays, Natixis and Mizuho) regarding the Federal Reserve Board’s enhanced prudential standards adopted under Section 165 of the Dodd-Frank Act and the implementation of enhanced capital requirements under the Basel Committee’s “Basel II,” “Basel II-1/2” and “Basel III.”

  • U.S. and international banks in connection with regulatory investigations by the Federal Reserve, FinCEN, OFAC and bank regulatory authorities regarding compliance with anti-money laundering requirements and U.S. sanctions programs.

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Transactional Highlights

  • The underwriters, led by Goldman Sachs, JPMorgan Chase and Morgan Stanley, in the initial public offering of shares of common stock of Citizens Financial Group — the largest-ever U.S. IPO of a retail bank.

  • Banner Corporation in its $702 million acquisition of Starbuck Bancshares, the bank holding company for AmericanWest Bank.

  • American Express in the formation of a 50/50 joint venture of its Global Business Travel division with an investor group comprised of BlackRock, Certares LP, Macquarie Capital Group and Qatar Holding.

  • Barclays Bank in the sale of all of the partnership interests in Barclays Private Credit Partners Fund L.P. to Ares Capital Corporation, a specialty finance company for private middle-market companies.

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Selected Activities

  • Member, Executive Council, Banking Law Section of the Federal Bar Association