Hugh C. Conroy, Jr.’s practice focuses on bank and bank holding company regulatory issues, and he provides advice to both U.S. and non-U.S. financial institutions on a range of related issues.

He currently devotes a significant portion of his practice to advice and advocacy regarding the Dodd-Frank Act and rules promulgated thereunder, including those related to capital, liquidity, the Volcker Rule, and banking regulation of derivatives and securities financing transactions.

His practice more generally encompasses bank and bank holding company regulatory issues arising out of complex structured finance transactions; derivative and structured derivative products; securities and commodities trading; new products and activities; mergers and acquisitions; private equity investments; and internal corporate reorganizations.

From 2004 to 2011, Hugh served as associate general counsel, becoming a managing director in Citigroup’s Bank Regulatory Office in 2010. He was responsible primarily for U.S. bank and bank holding company regulatory advice to Citigroup’s global corporate and investment bank (particularly its sales and trading desks), and provided advice globally to Citigroup’s widespread operations. Prior to joining Citigroup, he was an associate at another major law firm from 1996 to 2004.

Hugh joined the firm as counsel in 2011 and became partner in 2018.

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Notable Experience

  • Multiple digital asset custodians on the development of structures that ensure the bankruptcy remoteness of custodied assets

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

  • Regular outside counsel to American Bankers Association Securities Association (ABASA) on matters related to regulatory reform initiatives.

  • The Institute of International Bankers with respect to their advocacy before government agencies on Dodd-Frank matters on behalf of international banks, including in connection with the Volcker Rule and the Federal Reserve’s enhanced prudential standards.

  • Several U.S. and non-U.S. institutions in developing strategies for capital and liquidity compliance under U.S. Basel III rules, including representation of central counterparties in qualifying for favorable treatment under capital guidelines.

  • Several major foreign banks on potential structural approaches to the conduct of their cross-border banking and securities activities in the United States, including potential “re-banking” scenarios and other alternatives.

  • Numerous financial institutions in matters related to the structure and scope of regulated activities, including the implementation and operation of capital markets, commodities, financial intermediation, and other bank and non-bank activities.

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Selected Activities

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  • Presents on bank regulatory issues and current events in the banking industry at conferences sponsored by the American Bankers Association, the American Bar Association, the Financial Markets Association, and the Securities Industry and Financial Markets Association, and has been a guest lecturer on bank regulatory matters at Columbia University School of Law and New York University School of Law.
  • Faculty; Financial Institutions, Markets, and Transactions Training Series; 2022 to 2023
  • Vice-chairman, American Bar Association Banking Law Committee, 2014 to 2017
  • Chairman of the Securities, Capital Markets and Derivatives Subcommittee, American Bar Association Banking Law Committee (2010 to 2013) and vice-chairman of the same subcommittee (2007 to 2010).
  • Faculty member, “Fundamentals of Banking Law” intensive seminar, co-sponsored by Boston University School of Law and UC-Berkeley School of Law (2015 to present).
  • Associate at an international law firm in New York, 1996 to 2004.
  • Fulbright Scholar, Kanazawa University, Japan, 1992 to 1993.

Publications

“Agencies Adopt Final Guidance for Resolution Plans of Domestic and Foreign Triennial Full Filers,” Cleary Gottlieb Alert Memo, August 9, 2024 (co-author).

“FCID Adopts New Final Rules for IDI Resolution Plans,” Cleary Gottlieb Alert Memo, June 28, 2024 (co-author). 

“AI May Do Wonders for Your Business, But What About Your Risk Profile?” Cleary Gottlieb Selected Issues for Boards of Directors in 2024, January 17, 2024 (co-author). 

“Second Circuit Affirms Syndicated Loans Are Not Securities, Avoiding Market Disruption,” Cleary Gottlieb Alert Memo, September 21, 2023 (co-author). 

“U.S. Banking Agencies Propose Increases to Capital Requirements of Banking Institutions,” Cleary Gottlieb Alert Memo, July 28, 2023 (co-author). 

“Recent Bank Failure Reports Point to Increased Scrutiny of U.S. Banks,” Cleary Gottlieb Alert Memo, May 9, 2023 (co-author).

“What Happens if Congress Fails to Raise or Suspend the Debt Ceiling: How Market Participants Can Prepare for a Worst Case Scenario,” Cleary Gottlieb Alert Memo, January 25, 2023 (co-author).

“Agencies Seek Comment on Large Bank Resolution,” Cleary Gottlieb Alert Memo, May 18, 2021 (co-author).

“FDIC Issues Cease and Desist Letters to Companies for Crypto-Related Representations About Deposit Insurance,” Cleary Enforcement Watch blog, August 29, 2022 (co-author).

“FDIC and CFPB Adopt Sweeping Guidance on Deposit Insurance Advertising,” Cleary Gottlieb Alert Memo, June 6, 2022 (co-author).

“U.S. Banking Agencies Issue Roadmap for Crypto Regulation,” Cleary Gottlieb Alert Memo, November 30, 2021 (co-author).

“Federal Reserve Finalizes Expansion of Regulation EE’s “Financial Institution” Definition,” Cleary Gottlieb Alert Memo, March 8, 2021 (co-author).

“FDIC Overhauls Brokered Deposit Regulation,” Cleary Gottlieb Alert Memo, January 25, 2021 (co-author).  

“OCC Standardizes Rules for Complex Activities and Updates Licensing Procedures,” Cleary Gottlieb Alert Memo, December 28, 2020 (co-author).

“Agencies Finalize Resolution Plan Guidance for Certain Foreign Banks,” Cleary Gottlieb Alert Memo, December 21, 2020 (co-author). 

“Key Areas to Watch in Financial Institution Regulation Under President Biden,” Cleary Gottlieb Alert Memo, November 13, 2020 (co-author). 

“Agencies Require Deduction of TLAC Debt Held by Category I and II Banking Organizations,” Cleary Gottlieb Alert Memo, November 04, 2020 (co-author).

“Guide 3 Requirements for Banking Registrants Codified,” Cleary Gottlieb Alert Memo, September 16, 2020 (co-author) 

“Prudential Regulators Amend Non-Cleared Swap Margin Requirements,” Cleary Gottlieb Alert Memo, June 30, 2020 (co-author).

“Federal Reserve Curtails Stock Buybacks and Caps Large Bank Dividends,” Cleary Gottlieb Alert Memo, June 26, 2020 (co-author).

“OCC Looks to Expand Digital Banking and Proposes Updates to Bank Activity Regulations,” Cleary Gottlieb Alert Memo, June 12, 2020 (co-author).

“Federal Reserve Releases Details of Main Street Lending Program,” Cleary Gottlieb Alert Memo, June 1, 2020 (co-author), republished by The Columbia Law School Blue Sky Blog, June 8, 2020

“SDNY Holds Syndicated Loans Are Not Securities, Rejecting Challenge That Threatened to Disrupt $2 Trillion Market During COVID-19 Crisis,” Cleary Gottlieb Alert Memo, May 26, 2020 (co-author). 

“FDIC Approves Two New ILCs and Proposes Supervision of ILC Parents,” Cleary Gottlieb Alert Memo, March 26, 2020 (co-author).

“Summary of U.S. Financial Sector Initiatives Responding to COVID-19,” Cleary Gottlieb Alert Memo, March 26, 2020 (co-author).

“DFS Regulation Clarifies Scope of Governor Cuomo’s Forbearance Order,” Cleary Gottlieb Alert Memo, March 25, 2020 (co-author).

“Comprehensive Summary of U.S. Financial Sector Initiatives Responding to COVID-19,” Cleary Gottlieb Alert Memo, March 24, 2020 (co-author).

“Response to COVID-19: Break Out the Financial Crisis Toolkit?,” Cleary Gottlieb Alert Memo, March 17, 2020 (co-author).

“Federal Reserve’s Final Rule on “Control”: Observations and Analysis,” Cleary Gottlieb Alert Memo, February 25, 2020 (co-author).

“Observations on the Volcker Funds Proposal,” Cleary Gottlieb Alert Memo, February 12, 2020 (co-author).

“Federal Banking Agencies Release Foreign Bank Tailoring Proposals,” Cleary Gottlieb Alert Memo, April 2019, (co-author).

“Volcker Rule “1.5”: Reconsidering the Scope of the Rule,” Butterworths Journal of International Banking and Financial Law, October 1, 2018 (co-author)

“Cleary Gottlieb Discusses New Law Revising Dodd-Frank Act,” Columbia Law School Blue Sky Blog, May 2018 (co-author).

“Volcker 1.5: Highlights of Proposal to Simplify the Volcker Rule,” Cleary Gottlieb Alert Memo, May 2018, (co-author), republished by the Harvard Law School Forum on Corporate Governance and Financial Regulation, June 15, 2018.

“Federal Reserve Proposes “Stress Capital Buffer” and Scales Back eSLR,” Cleary Gottlieb Alert Memo, April 2018, (co-author).

“Senate Passes Regulatory Relief Bill,” Cleary Gottlieb Alert Memo, March 2018, (co-author).

“Guide to Bank Underwriting, Dealing and Brokerage Activities,” Thomson Reuters, 17th-22nd eds., 2012-2018 (co-author). 

“OCC Seeks Input on Revising Volcker Regulations,” Cleary Gottlieb Alert Memo, August 2017, republished by the Banking Law Journal, November/December 2017. 

“A Modest Proposal?  Treasury’s Report on Bank Regulation,” Cleary Gottlieb Alert Memo, June 2017, republished by the Harvard Law School Forum on Corporate Governance and Financial Regulation, June 2017.

“U.S. Regulation of International Activities of U.S. Banking Organizations,” Regulation of Foreign Banks & Affiliates in the United States, 6th-9th eds., 2012-2016 (co-author).

“Spotlight on Fed’s Stance On Chinese Control of U.S. Banks,” Law360, June 2012 (co-author).

Events