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Pryor Cashman’s Raice and Dwyer Author New BNA Banking Practice Portfolio on Intra-Agency Appeals and Administrative Enforcement Actions

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Partner Pinchus Raice, a member of Pryor Cashman’s Banking & Finance, Corporate and Litigation groups and leader of the Financial Institutions practice, and Associate Meghan Dwyer, a member of the Banking & Finance and Corporate groups, have authored a new portfolio for the Bloomberg BNA Banking Practice Portfolio Series.

The portfolio, Intra-Agency Appeals and Administrative Enforcement Actions, 405 Banking Practice Portfolio Series (BNA), discusses the mechanism by which financial institutions can appeal certain determinations made by their federal supervisory agency and provides a series of hypothetical cases studies to illustrate how a bank may appeal such determinations.

In addition, the portfolio discusses certain informal and formal enforcement actions, summarizes Supervision Appeals Review Committee (SARC) rulings since 2005, and provides a timeline for the appeal of formal enforcement actions.