Lawrence D. Fruchtman

Larry Fruchtman is a highly knowledgeable bank regulatory attorney who complements his legal practice with perspective gained from c-suite bank leadership. His 40-plus years of experience offer unique insights and a thorough understanding of bank regulatory challenges, as well as bank operational and transactional matters.

What do you focus on?

I help bank leaders navigate both the everyday and bet-the-company operational and transactional issues they contend with in the complex, risk-focused regulatory environments of insured depository institutions. After many years of legal practice, I have a depth of experience in domestic and foreign financial services regulatory and transactional matters from the vantage of the Federal Reserve, as well as inside and outside counsel positions. I have addressed matters under the Bank Holding Company Act of 1956, as amended, and navigated affiliate and insider transactions, lending limits and permissible bank investments, regulatory capital, anti-tie-in rules and many other financial services regulatory matters.

I have spent the last decade as an executive vice president and general counsel of a unique, union-owned $3.7 billion asset commercial bank and its institutional Taft-Hartley trust department—with over $30 billion in assets under management or in custody—while also handling a variety of matters, including assisting with a $100 million private equity capital raise. Prior to that, I was special counsel at a large New York City law firm where I provided advice to foreign and domestic clients on bank regulatory matters and also prepared the firm’s extensive memorandum on the Gramm-Leach-Bliley Act. For the first ten years of my practice, I practiced as an attorney and officer of the Federal Reserve Bank of New York.

What do you see on the horizon?

The challenges facing insured depository institutions and other financial services businesses have never been greater. The low interest rate environment has placed a significant strain on margins while, at the same time, these institutions are subject to significantly greater regulatory burdens and capital constraints on their ability to take risks and make money. Although the most onerous of those requirements fall on the largest financial institutions, I have seen and anticipate that elements of these requirements will be applied to smaller institutions. In addition, I expect to see continued growth in the less regulated part of the financial services industry, while the types of regulation normally applied to insured depository institutions expand to the broader financial services market.

Areas of ongoing and future concern include:

  • Onerous anti money laundering requirements coupled with regulatory pressure to serve high risk money services businesses
  • Requirements to record and address customer complaints
  • Developing the systems to comply with revised consumer and wholesale banking regulations
  • Limits on leveraged finance and bars to proprietary trading and certain fund investments by insured depository institutions
  • More restrictive and complex capital requirements
  • Newly mandated liquidity requirements and stress testing
  • Requirements that systemically important financial institutions provide roadmaps to their resolution in the event of insolvency

OCC rule misaligned with some tax equity safe harbors

Law360 | March 08, 2021

This contributed article, which examines the OCC’s finalized rule governing national banks’ ability to participate in equity-based finance structures involving tax credits, was authored by Project Finance & Public Finance partner Ellen Friedman and Global Finance senior counsel Larry Fruchtman, both in New York City; Community Development Finance partner Forrest Milder in Boston; and Community Development Finance partners Michael Goldman and Shariff Barakat, both in Washington, DC.

Federal rule opens tax-equity investment to national banks

Inframation News | January 25, 2021

This article on the new rule by the Office of the Comptroller of the Currency that may allow national banks and federal savings associations to engage in certain tax-equity finance transactions cites a recent NP tax credit alert. The alert was written by Project Finance & Public Finance partner Ellen Friedman and Global Finance senior counsel Larry Fruchtman, both in New York City; Community Development Finance partners Shariff Barakat and Michael Goldman, both in Washington, D.C.; and Boston Community Development Finance partner Forrest Milder.


Lawrence D. Fruchtman

Senior Counsel

New York

Phone: 212-940-3015

University of Michigan Law School, J.D.

University of Michigan Graduate School, M.A.

City College of New York, B.A., cum laude

New York

U.S. District Court, Southern District of New York

U.S. Court of Appeals, Second Circuit

Larry Fruchtman is a member of the American Bar Association, New York State Bar Association, Banking Law Committee and the Association of the Bar of the City of New York.

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