Chief Counsel's Office (2023)

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    Chief Counsel's Office (1)

    The primary mission of the OCC's Law Department is to provide high quality and timely work efficiently and effectively in support of the agency's goals and strategic objectives, including the following:

    • Provide legal analyses and interpretations, consistent with law and regulation, that support a safe and sound, vibrant, and diverse system of national banks and federal savings associations; and that encourage responsible innovation in the banking industry to meet the needs of consumers, businesses and communities.
    • Provide legal support for administrative actions to enforce compliance with applicable laws and regulations and safe and sound practices by national banks, federal savings associations, and institution-affiliated parties, as necessary.
    • Provide legal advice on the application of consumer laws and regulations to ensure that consumers have fair access to financial services and are treated fairly.
    • Provide legal counsel and support on a broad range of federal laws that apply to national banks' and federal savings associations' capital markets and trust/fiduciary activities.
    • Analyze legislation affecting national banks, federal savings associations, and OCC agency operations.
    • Provide drafting support and legal advice with respect to OCC rulemakings.
    • Provide legal advice on international banking issues and prepare cross-border agreements to support collaboration with international regulators on the identification of systemic risk and the efficient supervision of financial systems.
    • Represent the Comptroller of the Currency in litigation involving OCC's decisions and operations, the National Bank Act, and the Home Owners Loan Act.
    • Provide legal support for timely and sound decisions on corporate applications in support of a vibrant, diverse, and innovative system of national banks and federal savings associations.
    (Video) Tax Careers: The Office of Chief Counsel & the IRS


    First NameLast NameTitleSupport StaffPhone
    Benjamin W.McDonoughSenior Deputy Comptroller and Chief CounselExecutive Staff Assistant to the Senior Deputy Comptroller and Chief Counsel: Cynthia Jenkins(202) 649-5400
    TedDowdDeputy Chief CounselMichelle Hewitt(202) 649-5400
    JonathanFinkAssociate Chief CounselMichelle Hewitt(202) 649-5400
    StephenLybargerDeputy Comptroller for LicensingExecutive Assistant to the Deputy Comptroller for Licensing: Sandra Hart(202) 649-6260
    PatriciaGradyDeputy Chief CounselMichelle Hewitt(202) 649-5400


    The Administrative and Internal Law group:

    • Serves as the OCC's counsel on a variety of matters affecting the administration of the Agency's business:
      • Provides counsel to the OCC's Office of Management regarding procurement matters (including bid protests), lease negotiations and lease terms for offices across the United States, and financial matters, including federal tax law and federal travel regulations;
      • Provides advice regarding Freedom of Information Act (FOIA) appeal decisions, administration of the Privacy Act, delegations of authority, and information sharing and disclosure;
      • Provides counsel to OCC managers on employment law, labor relations law and collective bargaining issues; represents the OCC at labor arbitrations and at administrative proceedings before the Federal Labor Relations Authority;
      • Provides counsel to Equal Employment Opportunity staff and OCC managers regarding equal employment law; and
      • Provides guidance to the Chief Counsel in administering the OCC ethics program.
    Administrative and Internal Law(202) 649-5400
    VacantAssistant Director
    (Video) Chief Counsel Johnnie Barton Introduces the Office of Open Government

    The Bank Advisory group:

    (Video) IRS Office of Chief Counsel's first National Virtual Settlement Month successful in resolving

    • Serves as the OCC's counsel on a broad range of activities and corporate structures of national banks, federal savings associations and federal branches and agencies:
      • Advises licensing on matters including charters, mergers and acquisitions, changes in control, operating and financial subsidiaries, and non-controlling investments in other entities;
      • Provides counsel relating to the ongoing activities of national banks and federal savings associations that could present operational risks affecting their safety and soundness, including electronic banking, third-party service providers, lending limits, affiliate transactions, and real estate and leasing activities;
      • Provides legal support with respect to problem bank and resolution matters in both domestic and cross-border contexts, including receiverships, conservatorships, and voluntary liquidations; and
      • Coordinates with other federal financial agencies, including the Federal Reserve Board, the Federal Deposit Insurance Corporation, the Federal Financial Institutions Examination Council, and the Financial Stability and Oversight Council on resolution issues.
    • Serves as the OCC's counsel on a wide range of consumer-related issues:
      • Advises the OCC's supervisory, compliance, licensing, enforcement, community affairs, and customer complaint resolution units regarding consumer protection, fair lending, and community development and Community Reinvestment Act matters, as they apply to national banks and federal savings associations;
      • Advises other groups within the Law Department and lines of business regarding fair access to bank services, bank community development powers and community reinvestment activities; and
      • Collaborates internally with OCC lines of business and externally with the Consumer Financial Protection Bureau, the other federal banking agencies, and other responsible governmental agencies regarding the development, implementation, and consistent application of consumer-related regulations and policy guidance.
    • Serves as the OCC's counsel on legislative and regulatory matters:
      • Develops and drafts the OCC's regulations and provides legal counsel for the agency's compliance with the various federal statutes and, where applicable, executive orders that govern the rulemaking process;
      • Monitors pending legislation of significance to national banks, federal savings associations, or the OCC, and provides legal support for the agency's legislative work;
      • Provides legal advice on international banking issues relating to foreign banks' federal branches or agencies in the United States and the foreign operations of national banks and federal savings associations;
      • Provides legal advice on issues relating to national banks' and federal savings associations' regulatory capital requirements; and
      • Provides legal advice on issues relating to cybersecurity as it affects national banks and federal savings associations.
    • Serves as the OCC's counsel on a broad range of banking, securities, commodities, and corporate governance matters:
      • Drafts legal memoranda, opinions, and interpretive letters;
      • Advises examiners, policy staff, and banks on matters including capital markets activities (e.g., commodities, securities, derivatives, central counterparties, and structured finance); asset management activities (e.g., trust, fiduciary, custody, and prime brokerage); Dodd–Frank Act provisions (e.g., the Volcker Rule and Title VII's amendments to the securities laws and the Commodity Exchange Act); accounting; annuities, insurance and debt cancellation contracts; and tying;
      • Provides subject matter expertise with respect to analyzing legislation, and enforcement and litigation matters; and
      • Coordinates with the Securities and Exchange Commission, the Commodity Futures Trading Commission, the federal banking agencies, and other regulatory agencies regarding rulemaking, legal interpretations, etc.
    Bank Advisory(202) 649-5490
    Stuart FeldsteinDirector, Bank Advisory
    Eden GrayAssistant Director
    Carl KaminskiAssistant Director
    Beth KirbyAssistant Director
    Kathryn RayAssistant Director
    Valerie SongAssistant Director
    Patrick TierneyAssistant Director

    These Legal Offices:

    • On matters delegated to them, serve as frontline legal advisors to Deputy Comptrollers and bank examiners:
      • Provide legal advice to examination teams;
      • Provide banking companies, bank counsel, and law firms with information and clarification regarding OCC rules, policies, and other matters affecting their institutions or clients;
      • Liaise with representatives of state banking departments and other local offices of federal and state agencies regarding issues of mutual interest;
      • Provide legal support on enforcement actions;
      • Conduct legal training programs for examiners;
      • Represent the Law Department as speakers at seminars and conferences; and
      • Prepare a variety of corporate opinions and legal advisory letters.
    Chicago(312) 360-8805
    Damon J. SavoyDistrict Counsel
    Dallas(214) 720-7012
    Randy RyskampDistrict Counsel
    Javier MaymirAssistant District Counsel
    Denver(720) 475-7630
    Kimberley FolkActing District Counsel
    New York(212) 790-4010
    Jonathan RushdoonyDistrict Counsel

    The Enforcement group:

    • Serves as the OCC's counsel on matters related to investigations, enforcement actions, and administrative litigation:
      • Conducts formal and informal investigations;
      • Advises on whether OCC-supervised institutions and institution affiliated parties (IAPs) have engaged in unsafe or unsound banking practices, violations of laws and regulations, or breaches of fiduciary duty;
      • Handles matters involving Bank Secrecy Act/Anti-Money Laundering law violations, consumer law violations, and fraud related actions, among other areas;
      • Advises the OCC's supervisory, compliance, and licensing units on the legal requirements for enforcement actions and on enforcement-related policies and procedures;
      • Litigates all OCC enforcement actions before the Office of Financial Institution Adjudication (OFIA), including civil money penalties, prohibitions and removals, and cease-and-desist orders;
      • Refers criminal acts involving OCC-supervised institutions or IAPs to the U.S. Department of Justice; and
      • Coordinates with the federal banking agencies; and other regulatory agencies, including the Financial Crimes Enforcement Network, the U.S. Securities and Exchange Commission, and the Consumer Financial Protection Bureau on matters involving OCC-supervised institutions.
    Enforcement(202) 649-6200
    Monica FreasDirector of Enforcement
    William JauquetAssistant Director
    Larry KeenAssistant Director
    Liz RatliffAssistant Director
    (Video) IRS Office of Chief Counsel unveils National Virtual Settlement Days effort this year

    The Licensing Division is responsible for ensuring that the corporate structure of national banks and federal savings associations is established and maintained in accordance with the principles of a safe and sound banking system. In this role, Licensing receives, analyzes, and decides filings to establish, change the structure of, or change the activities performed by national banks, federal savings associations, and federal branches and agencies. Licensing works closely with the agency’s supervisory and legal divisions to render independent decisions, supported by a strong record of facts and in compliance with applicable laws and regulations. Filings, other submissions, or questions should be addressed to the appropriate OCC licensing office.

    (Video) Chief Counsel Johnnie Barton on the Office of Open Government’s Mission

    Licensing(202) 649-6260
    Stephen LybargerDeputy Comptroller for Licensing
    Yoo Jin NaDirector for Licensing Activities
    Jason AlmonteDirector for Large Bank Licensing
    Carolina LedesmaDirector for Licensing
    Debra M. BurkeDirector for Licensing
    Sebastian R. AstradaDirector for Licensing

    The Litigation group:

    • Serves as the OCC's counsel in a variety of forums:
      • Represents the OCC in court;
      • Represents the OCC in the administrative phase of personnel actions (e.g., Equal Employment Opportunity (EEO), Merit Systems Protection Board);
      • Administers the OCC's regulations regarding confidential supervisory information;
      • Advises the Comptroller regarding administrative law judge decisions appealed to the Comptroller, and drafts the Comptroller's decision document;
      • Provides litigation risk advice; and
      • Participates in the preparation of the legal memorandums necessary for problem bank resolutions.
    Litigation(202) 649-6300
    Greg TaylorDirector
    Peter KochAssistant Director
  • FAQs

    Chief Counsel's Office? ›

    The Chief Counsel's Office (CCO) provides assistance to the Division, the Commission, and the public interpreting the Investment Company Act of 1940

    Investment Company Act of 1940
    Investment Company Act of 1940

    This Act regulates the organization of companies, including mutual funds, that engage primarily in investing, reinvesting, and trading in securities, and whose own securities are offered to the investing public. › investment › laws-and-rules
    (Investment Company Act), the Investment Advisers Act of 1940 (Advisers Act), their related rules, and other federal securities laws that apply to investment companies and ...

    What does IRS Office of Chief Counsel do? ›

    Attorneys in the Chief Counsel's Office serve as lawyers for the IRS. They provide the IRS and taxpayers with guidance on interpreting Federal tax laws correctly, represent the IRS in litigation, and provide all other legal support required to carry out the IRS mission.

    What is IRS Chief Counsel advice? ›

    Chief Counsel Advice is a term used to describe a certain subset of legal advice that is required to be released to the public under IRC 6110. Not all legal advice is subject to this public disclosure requirement.

    Who is the White House Office of Chief Counsel? ›

    The White House counsel is a senior staff appointee of the president of the United States whose role is to advise the president on all legal issues concerning the president and their administration.
    White House Counsel
    Incumbent Stuart Delery since July 2022
    First holderSamuel Rosenman

    Who is the Chief Counsel of the California Energy Commission? ›

    Linda Barrera | California Energy Commission.

    Who is acting IRS Chief Counsel? ›

    Principal Deputy Chief Counsel and Deputy Chief Counsel (Technical) William M. Paul assumed the position of Acting Chief Counsel on January 20, 2021 upon the resignation of former Chief Counsel Michael J. Desmond.

    How many people work for IRS Chief Counsel? ›

    We are the largest tax firm in the country with approximately 1,500 attorneys. As an attorney in the Office of Chief Counsel you will work with and learn from some of the best legal tax minds in the country.

    Can a tax attorney negotiate with IRS? ›

    A tax attorney can help you deal with the IRS. Depending on your situation, they can help you negotiate an offer an compromise, remove penalties, set up payments, or protect your assets from collection actions. An attorney leverages their experience to get you the best outcome possible.

    How do I escalate an IRS issue? ›

    You can file Form 911, Request For Taxpayer Advocate Service Assistance (And Application for Taxpayer Assistance Order), or ask an IRS employee to complete it on your behalf. For more information, go to Taxpayer Advocate Service.

    What is IRS Chief Counsel Advice 200108042? ›

    In Chief Counsel Advice (CCA) Memorandum 200108042, which the IRS issued on December 20, 2000, the IRS said that non-monetary recognition awards having a fair market value of $100 do not qualify as de minimis fringes.

    Who is President Trump's chief Counsel? ›

    Don McGahn
    Political partyRepublican
    SpouseShannon McGahn
    EducationUniversity of Notre Dame (BA) Widener University (JD) Georgetown University (LLM)
    22 more rows

    How much do White House advisors make? ›

    The maximum salary allowed for any White House aide is $183,000. This is, in fact, the salary that senior advisers Kellyanne Conway and Larry Kudlow (Trump's top economic adviser) earn.

    Who is the White House Counsel under Biden? ›

    Dana Remus
    BornNew Hampshire, U.S.
    Political partyDemocratic
    SpouseBrett M. Holmgren ​ ( m. 2018)​
    EducationHarvard University (BA) Yale University (JD)
    10 more rows

    Who is General Counsel of PG&E? ›

    John Simon - Executive Vice President, General Counsel and Chief Ethics and Compliance Officer - PG&E Corporation | LinkedIn.

    Who is the CIO for the state of California? ›

    Liked by Liana Bailey-Crimmins.

    What does the California Energy Commission do? ›

    The Energy Commission helps ensure that proposed energy facilities are located, constructed, operated, and decommissioned in a manner that protects the environment, public health, and safety. In addition, the Commission performs transmission infrastructure planning.

    What is the highest position in IRS? ›

    An IRS officer could rise up to the Apex Scale (₹2,50,000 fixed plus allowances) at the post of principal chief commissioner of income tax in the ITD. At the apex level, he can also get selected as a Member or Chairperson of the CBDT.

    Who are the top officials in the IRS? ›

    Human Capital Officer — David M. Aten * Chief Financial Officer — Teresa Hunter. Chief Privacy Officer — Kathleen Walters.

    Who does the IRS report to? ›

    GAO. The Government Accountability Office (GAO) is an agency that works for Congress and the American people.

    What is the highest paid IRS agent? ›

    Irs Agent Salary
    Annual SalaryMonthly Pay
    Top Earners$100,000$8,333
    75th Percentile$70,500$5,875
    25th Percentile$37,500$3,125

    How much does the IRS pay agents? ›

    As of May 9, 2023, the average annual pay for an Irs Agent in California is $64,363 a year. Just in case you need a simple salary calculator, that works out to be approximately $30.94 an hour. This is the equivalent of $1,237/week or $5,363/month.

    How much will IRS agents make? ›

    Average IRS Revenue Agent yearly pay in the United States is approximately $70,851, which is 9% above the national average. Salary information comes from 253 data points collected directly from employees, users, and past and present job advertisements on Indeed in the past 36 months.

    How much will the IRS usually settle for? ›

    How much will the IRS settle for? The IRS will typically only settle for what it deems you can feasibly pay. To determine this, it will take into account your assets (home, car, etc.), your income, your monthly expenses (rent, utilities, child care, etc.), your savings, and more.

    Can I negotiate with the IRS myself? ›

    Apply With the New Form 656

    An offer in compromise allows you to settle your tax debt for less than the full amount you owe. It may be a legitimate option if you can't pay your full tax liability or doing so creates a financial hardship. We consider your unique set of facts and circumstances: Ability to pay.

    Will the IRS take a settlement? ›

    It does happen, but only in cases where a taxpayer clearly does not have the assets and/or income to pay off the tax debt in a reasonable time. If you have the money to pay the IRS--or will likely have it in the future--no amount of negotiating will convince the IRS to settle for less than you owe.

    Can I sue the IRS for not responding? ›

    Because the United States government has sovereign immunity, you can't sue the IRS for other things like emotional distress.

    Does the IRS take complaints seriously? ›

    Mail to IRS EO Classification, Mail Code 4910DAL, 1100 Commerce St., Dallas, TX 75242-1198 Fax to 214-413-5415, or Email to The IRS takes all complaints seriously and scrutinizes all referrals. For more information, go to: www/

    How do you tell if IRS is investigating you? ›

    Sometimes you may receive a formal notice from the IRS in the mail that proclaims you are under investigation. This could be a letter that simply states that you are under an IRS audit, or it could be a subpoena for records or a summons to appear for a formal interview.

    What is Chief Counsel Advice 202204007? ›

    In a recently published chief counsel memorandum (CCA 202204007), the IRS concluded that a business that facilitates property rentals between lessors and lessees is providing brokerage services within the meaning of IRC Section 1202(e)(3)(A). Facts.

    What is IRS Chief Counsel Advice 202114020? ›

    The recently released IRS Chief Counsel Advice 202114020 takes aim at that argument, stating that the receipt of new cryptocurrency units as a result of a hard fork is taxable to the recipient at applicable (individual or corporate) rates, regardless of how the new units are distributed or otherwise made available.

    What is Chief Counsel Advice 200026025? ›

    In a Chief Counsel Advice memorandum (No. 200026025, released on June 30, 2000), our office considered the proper application of the 1-year limitation when a taxpayer performs services at a location on a recurring, but infrequent or sporadic, basis for a period of more than one year.

    Who was Obama's White House Counsel? ›

    Warren Neil Eggleston (born July 5, 1953) is an American lawyer who served as the White House Counsel under President Barack Obama. Eggleston was the fourth person to hold this post during the Obama administration. Evansville, Indiana, U.S.

    Who was the White House counsel under Trump? ›

    Pat Cipollone
    BornPasquale Anthony Cipollone May 6, 1966 New York City, New York, U.S.
    Political partyRepublican
    SpouseRebecca Thelen
    11 more rows

    What is Trump's lawyers name? ›

    Joe Tacopina, the bulldog defense attorney.

    Does the first lady get paid? ›

    The first lady is not an elected position; it carries no official duties and receives no salary. Nonetheless, she attends many official ceremonies and functions of state either along with or in place of the president.

    What is the highest paying job at the White House? ›

    President Donald Trump earns $400,000 per year, while Vice President Mike Pence makes $230,700 annually. The highest-paid employee — excluding the president — is John Czwartacki, with a $239,595 salary, while Christopher Liddell is the lowest-paid employee with a $30,000 salary.

    How much does the president's body man make? ›

    The body man often travels with the president, and is also his go-to person if he needs newspapers, briefings, and even pens, Politico reported. President Trump's first body man, John McEntee, made $115,000 in 2017.

    Who is the top advisor to the president? ›

    Senior Advisor Valerie Jarrett |

    Who is bidens top advisors? ›

    White House Office
    OfficeAppointeeAssumed office
    Office of the White House Chief of Staff
    — Senior Advisor to the PresidentMike DonilonJanuary 20, 2021
    Neera TandenMay 17, 2021
    Anita Dunn
    120 more rows

    Who is the staff of the White House counsel? ›

    Office of the White House Counsel
    • Chief of Staff to the White House Counsel: Jennifer Sokoler. Deputy Chief of Staff to the White House Counsel: Caroline Saba.
    • Special Assistant to the White House Counsel: Katie Reilly.
    • Special Assistant to the President and Spokesperson for the White House Counsel's Office: Ian Sams.

    How much do PG&E executives make? ›

    In 2021 PG&E CEO Patricia Poppe was paid $51.2 million.

    Does the government own PGE? ›

    A state-owned and community-controlled PG&E means safe, reliable, affordable electricity that can jump start a California Green New Deal.

    Who is General Counsel of Exelon? ›

    Gayle Littleton - Executive Vice President, General Counsel - Exelon Corporation | LinkedIn.

    Who was CIO under Obama? ›

    Federal Chief Information Officer (CIO) Before his appointment as CIO, Mr. Kundra served as technology adviser on President Barack Obama's transition team. Kundra was officially named by President Obama on March 5, 2009, to the post of Federal CIO.

    Is the CIO under the CEO? ›

    In many companies, the CIO reports directly to the chief executive officer (CEO), and at some companies the CIO sits on the executive board.

    Who is the CIO for the government? ›

    The CIO Council is a forum of Federal Chief Information Officers (CIOs). Our goal is to improve IT practices across U.S. Government agencies. is where we share our priorities, key technology policies, news, and the programs and events sponsored by our Council.

    Who is the head of the California Energy Commission? ›

    Drew Bohan | California Energy Commission.

    Who controls electricity in California? ›

    To ensure that the state's energy is safe, affordable, reliable, and clean, California has established three governing institutions: the California Energy Commission, the California Public Utilities Commission, and the California Independent System Operator.

    Who runs the California Energy Commission? ›

    J. Andrew McAllister, Ph.

    What is IRS Chief Counsel Advice 200026025? ›

    In a Chief Counsel Advice memorandum (No. 200026025, released on June 30, 2000), our office considered the proper application of the 1-year limitation when a taxpayer performs services at a location on a recurring, but infrequent or sporadic, basis for a period of more than one year.

    What is the hierarchy of the IRS? ›

    The IRS structure is divided into two primary organizations: the Deputy Commissioner for Services and Enforcement (DCSE) and the Deputy Commissioner for Operations Support (DCOS).

    What is Chief Counsel Advice 202117012? ›

    In Chief Counsel Advice 202117012[1] the IRS looks at issues surrounding the deduction of expenses related to the use of aircraft by a sole proprietor. Specifically, the ruling looks at whether the taxpayer uses: The primary purpose test found at Reg.

    What is Chief Counsel Advice CCA 202132009? ›

    Chief Counsel Advice (CCA) 202132009 considers whether a taxpayer (remitting taxpayer) that pays the branded prescription drug fee (pharma fee) and is reimbursed by members of the taxpayer's controlled group may exclude the reimbursement from gross income simply because the liability for the fee is joint and several.

    What is Chief Counsel Advice CCA 201624021? ›

    In Chief Counsel Advice (CCA) 201624021, the IRS affirmed that taxable asset acquisitions are "covered" transactions for acquirers but not for targets, and, therefore, targets are ineligible to deduct success-based transaction costs using the elective safe-harbor method because the election is available only for ...

    What is Chief Counsel Advice CCA 201323015? ›

    In Chief Counsel Advice (CCA) 201323015, the IRS ruled that a joint collaboration between two corporations was a partnership for U.S. federal tax purposes and the entity could not elect out of the application of subchapter K of the Code.

    What is Chief Counsel Advice 202035011? ›

    In addition, in Chief Counsel Advice 202035011, the IRS concluded that a taxpayer who receives convertible virtual currency in exchange for performing a microtask through a crowdsourcing platform has received consideration in exchange for performing a service.

    What is Chief Counsel Advice CCA 200949040? ›

    Chief Counsel Advice (CCA) 200949040 affirms the view held by many tax practitioners that an employment contingency within the bonus or incentive compensation plan prevents the all-events test from being met at year end under Sec.

    What is the highest salary of an IRS officer? ›

    Which IRS Officer ranks gets the highest salary per month? The Principal Chief Commissioner of Income Tax rank gets the highest Indian Revenue Services salary of Rs. 2,25,000.


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