Bao Nguyen and Ted Dowd Named Deputy Chief Counsels

WASHINGTON — The Office of the Comptroller of the Currency (OCC) today announced the selection of Bao Nguyen and Ted Dowd to serve as Deputy Chief Counsels.

Mr. Nguyen and Mr. Dowd will join Charles M. Steele as Deputy Chief Counsels in the OCC’s Office of the Chief Counsel.

“Bao and Ted bring energy, expertise, and deep knowledge of the legal foundation of the federal banking system,” said Comptroller of the Currency Joseph M. Otting. “The agency is fortunate to add such talented people to lead its legal team to support its work overseeing our national banks and federal savings associations.”

In making this announcement, the OCC is expanding the number of Deputy Chief Counsels from two to three to better distribute management responsibilities within the department. In addition to this personnel announcement the agency is in the process of recruiting a permanent Chief Counsel. Acting Chief Counsel Karen Solomon previously announced her intent to retire at the end of August 2018, and has been serving in that role since November 2017.

Mr. Nguyen will serve as the Principal Deputy Chief Counsel. In that role, he will be the OCC Law Department’s chief operating officer. He will supervise the Bank Activities and Structure division, the Community and Consumer Law division, and the Northeast district counsel office. He will be involved in strategic planning for the department and provide advice and counsel to the Chief Counsel and senior OCC executives. He joins the OCC from the Board of Governors of the Federal Reserve System where he served as Senior Counsel in the Legal Division. There, he was the lead attorney reviewing a number of significant banking mergers and acquisitions approved by the Federal Reserve in recent years and helped author regulations to implement provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act. Mr. Nguyen also played an important role in the Federal Reserve’s resolution planning work. He was detailed to the OCC from May 2017 through January 2018 as Special Counsel to the Comptroller of the Currency, and previously served as a Banking Fellow in the U.S. Senate. Mr. Nguyen earned his bachelor’s degree in history education from North Carolina State University and his law degree from the University of North Carolina at Chapel Hill, where he served as Executive Editor of the First Amendment Law Review.

Mr. Dowd will serve as Deputy Chief Counsel supervising the OCC’s Legislative and Regulatory Activities and Securities and Corporate Practices divisions and will oversee the Central and Western district counsel offices. He moves to this new role from serving as Director of the Securities and Corporate Practices division. In that role, Mr. Dowd oversaw the division that provides legal interpretations and advice to OCC policymakers, senior managers, and examiners on banking, securities, derivatives, and corporate governance matters. He has had the lead role for the Law Department in Volcker Rule implementation including completion of the proposed revisions to the Volcker rule. He has supervised the department’s legal work in areas including capital markets, investment securities, financial technology, Dodd-Frank rulemakings, and fiduciary matters. He also oversaw staff members responsible for legal issues related to national bank and federal savings association securities offerings and related disclosures. Prior to joining the OCC, Mr. Dowd served as a Senior Trial Attorney for the U.S. Commodity Futures Trading Commission (CFTC), Division of Enforcement. He represented the CFTC in numerous enforcement actions in federal court. Mr. Dowd received his law degree from the Catholic University of America, Columbus School of Law. He is also a graduate of Providence College.

Mr. Nguyen and Mr. Dowd take on these new roles in mid-June.

Mr. Steele continues to serve as Deputy Chief Counsel and will continue to supervise the Enforcement and Compliance, Litigation, and Administrative and Internal Law divisions, as well as the Southern district counsel office. Mr. Steele assumed these duties in October 2016.