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Randy Benjenk

Randy Benjenk is co-chair of Covington’s Financial Services Group and advises domestic and foreign banks, fintech companies, other financial services firms, and trade associations on bank regulatory, compliance, transactional, supervisory, enforcement, and public policy matters. Clients turn to Randy for strategic advice and advocacy on their most complex issues involving federal and state banking regulators.

Chambers USA has recognized Randy for his bank regulatory practice, noting that he has received “widespread praise” from clients. Clients describe him as “an outstanding bank regulatory lawyer” and say that “the quality of his legal work and his writing abilities were incredible” and that “he’s very easy to work with, knowledgeable and efficient.”

Randy regularly represents clients in a wide range of financial services regulatory settings, including:

Bank Activities and Prudential Regulation. Advising on novel bank activities, organizational structure, licensing, chartering, governance, capital, liquidity, and prudential regulatory matters, including issues of first impression before federal and state banking agencies.
Corporate Transactions. Advising on mergers and acquisitions, spinoffs, charter conversions, debt and equity issuances, strategic investments, partnerships, de novo bank formations, bank-fintech partnerships, and related regulatory applications, approvals, and disclosures.
Private Equity Investments. Advising on private equity investments in banks, bank investments in private funds, and fund structuring issues under the Volcker Rule, Bank Holding Company Act, and related banking laws and regulations.
Supervisory and Enforcement Matters. Representing clients in examination, supervisory, and enforcement matters involving safety and soundness issues, Community Reinvestment Act obligations, legal compliance, governance, and risk management requirements.
Sustainability and Debanking Laws. Helping financial institutions and industry groups navigate the expanding landscape of federal and state laws and investigations involving environmental, social, governance, reputational risk, fair access, and debanking-related policies.
Crisis Response. Helping clients navigate extraordinary events and market disruptions, including bank failures, pandemic-related governmental responses, liquidity events, and other firm-specific or industry-wide regulatory challenges.
Public Policy and Regulatory Advocacy. Advocating for changes to policies affecting the financial services industry, including in the context of U.S. banking legislation, federal banking agency rulemakings, state policy initiatives, and international regulatory standards.

On July 10, 2025, the Board of Governors of the Federal Reserve System (“FRB”) issued a request for comment on proposed revisions to its large financial institution (“LFI”) supervisory rating system (the “LFI Framework”).

If finalized as proposed, the revisions would allow large depository institution holding companies with only one…

Continue Reading Proposed Revisions to the Federal Reserve’s LFI Rating System

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Continue Reading OCC to Reconsider June 2020 Community Reinvestment Act Final Rule

Under the Biden administration, it is unlikely that major financial services legislation like a Dodd-Frank Act will pass in the next few years, especially if Republicans hold the Senate. The Biden Administration will nevertheless have significant opportunities to shape policy through the federal financial agencies. The adage that “personnel is…
Continue Reading Anticipated Changes in Financial Regulation

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Continue Reading OCC Interpretation Paves Way for Banks to Custody Cryptocurrency