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Randall D. Guynn


Randall D. Guynn

Financial Institutions
New York

Chair of Financial Institutions. Widely recognized as a leading bank regulatory and bank M&A lawyer, and as a thought leader on financial regulatory reform.

Randy, chair of our Financial Institutions practice, is one of the country’s top bank regulatory and bank M&A lawyers and a thought leader on financial regulatory reform. His rankings include Star Individual and Band 1 by Chambers and Hall of Fame by Legal 500 U.S.

He advises a wide range of financial services clients on their most critical transactions, business opportunities, corporate governance issues, and regulatory, supervisory and enforcement matters. His clients include all eight U.S. global systemically important banking groups, numerous regional banks and non-U.S. G-SIBs, fintechs and crypto-asset companies.

Randy’s practice includes strategic bank M&A and capital markets, legislative and regulatory reform, board and senior executive effectiveness, enforcement actions, congressional hearings, business transformations, bank chartering, resolution planning, payment systems, and stablecoins, cryptocurrency and other digital assets.

Experience highlights

Mergers & Acquisitions
  • JPMorgan Chase on its FDIC-assisted acquisition of First Republic Bank
  • A consortium of the 8 U.S. G-SIBs and 3 large regional banks in making a $30 billion deposit investment into First Republic Bank in an attempt to stabilize the bank
  • TIAA on its sale of TIAA Bank ($39 billion in assets) to PE funds
  • Charles Schwab on its:
    • $26 billion acquisition of TD Ameritrade
    • $1.8 billion acquisition of USAA’s Investment Management Company
Financial Regulation and Supervision
  • U.S. G-SIBs and various regional banks on numerous regulatory proposals, including involving the Basel III endgame, long-term debt, holding companies and IDI resolution plans 
  • A group of large regional banks on a comment letter on a proposal to subject them to a long-term debt requirement developed for G-SIBs
  • U.S. G-SIBs, regional banks and their boards on remediating risk management and board oversight in enforcement actions by Fed or OCC
  • CEOs and boards of G-SIBs and tech companies on congressional hearings, including by Senate Banking and House Financial Services
  • All U.S. G-SIBs, a non-U.S. G-SIB and several regional banks on their resolution plans, including as the principal designer of the single-point-of-entry recapitalization within resolution strategy
  • SIFMA comment letters on rules implementing the proprietary trading and covered funds portions of the Volcker Rule
  • GE Capital on the FSOC’s rescission of its nonbank SIFI designation
Fintech & Cryptocurrency
  • Crypto Council for Innovation, Circle and Coinbase on legislative proposals for a federal framework for regulating crypto assets including stablecoins
  • Several U.S. G-SIBs and other banks on proposed crypto activities
  • Meta Platforms on the Libra/Diem stablecoin project
  • Fintechs on strategic options including insured or uninsured banks, industrial loan companies and trust companies
COVID-19 Financial Assistance
  • U.S. Treasury on its emergency loans to airlines, airline ticket agents and national security companies
  • Numerous financial institutions on government assistance programs
2008 Financial Crisis
  • Federal Reserve Bank of New York on $250 billion capital purchase program and rescue of AIG
  • GSE on its conservatorship and $100 billion investment by the U.S. Treasury
  • Citigroup on all of its major crisis-related matters
  • Morgan Stanley on conversion into a bank holding company


FDIC revamps IDI resolution planning



Best Lawyers – “Lawyer of the Year,” Financial Services Regulation Law, New York City, 2023

Chambers Global – Banking & Finance: Mainly Regulatory, USA, Star Individual

Chambers USA – Financial Services Regulation: Banking (Compliance), Star Individual

Chambers USA – Financial Services Regulation: Financial Institutions M&A, Band 1

Legal 500 U.S. – Financial Services Regulation, Hall of Fame

IFLR1000 – Financial Services Regulatory, United States, Market Leader

Who’s Who Legal – Banking - Regulatory, Thought Leaders Global Elite

Who’s Who Legal – Banking - Finance, Global Leader

Who’s Who Legal – “Banking Lawyer of the Year,” 2014 and 2017

Law360 – “Banking MVP of the Year,” 2014


J.D., University of Virginia School of Law
  • Order of the Coif
  • Executive Editor, Virginia Law Review
B.A., Brigham Young University
  • with highest honors


Law Clerk, Hon. William H. Rehnquist, Supreme Court of the United States, 1985-1986
Law Clerk, Hon. J. Clifford Wallace, U.S. Court of Appeals, Ninth Circuit, 1984-1985

Professional history

  • Davis Polk since 1986
  • Chair, Financial Institutions Group, 2023-present
  • Co-head, Financial Institutions Group, 1994-2023

Qualifications and admissions

  • District of Columbia
  • State of New York
  • U.S. Supreme Court
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