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Charles C. Gray

Special Counsel

Charles C. Gray

Special Counsel
New York +1-212-558-4000+1-212-558-4000 +1-212-558-3588+1-212-558-3588
[email protected]
Charles C. Gray is a member of the Firm’s Financial Services Group. He focuses on advising financial services clients on a wide variety of bank regulatory, enforcement and Dodd-Frank implementation matters. With more than ten years of experience at the Federal Reserve and Treasury Department, Mr. Gray is a knowledgeable adviser and frequent speaker on bank regulatory law and policy, including in the areas of resolution planning, capital, liquidity and cross-border supervision of international financial firms.

Government Service
Prior to joining the Firm, Mr. Gray was a senior officer at the Federal Reserve Bank of New York, where he served from 2006-2016 during a historic period of financial crisis and post-crisis financial reform. As a member of the New York Fed’s Legal Group, Mr. Gray was actively involved in shaping and carrying out the Fed’s crisis-response measures. In 2010, Mr. Gray was seconded as a policy adviser to the U.S. Department of the Treasury, where he contributed to the drafting and development of the Dodd-Frank Act. Following passage of Dodd-Frank, Mr. Gray participated in a broad range of regulatory and supervisory efforts to implement the legislation, with a focus on provisions directed at ending the too-big-to-fail problem. Most recently, he served as Vice President in the Supervisory Policy area of the Financial Institution Supervision Group, where he developed and implemented financial regulatory policy with a focus on issues affecting large complex financial institutions. 

Mr. Gray was also active in international policy deliberations as the New York Fed representative on the Cross-Border Crisis Management Group of the Financial Stability Board (FSB), the group responsible for advancing G-20 policy efforts related to recovery and resolution planning for global systemically important banks. As co-chair of the Financial Stability Board’s Workstream on Funding in Resolution, Mr. Gray led a working group of 19 central banks, resolution authorities and supervisory authorities in the development and publication of the FSB’s Guiding Principles on the Temporary Funding Needed to Support the Orderly Resolution of a Global Systemically Important Bank (2016).

Earlier in his career at the Fed, Mr. Gray was active as an Enforcement Attorney on a number of large public enforcement cases dealing with violations of Bank Secrecy Act / Anti-Money Laundering and Office of Foreign Assets Control regulations, as well as cases involving trading misconduct and consumer violations.

Prior to law school, Mr. Gray served as a Professional Staff Member for the Banking and Financial Services Committee of the U.S. House of Representatives, where he worked for Chairman Jim Leach on the legislation ultimately enacted as the Gramm-Leach-Bliley Act of 1999. Following a judicial clerkship, Mr. Gray began his legal practice as an associate in Sullivan & Cromwell's Financial Services Group from 2003 to 2006.

Selected Speaking Engagements
  • Liquidity Support and Exit Strategies in the New Resolution Framework, Executive Seminar on Banking Resolution – European University Institute, Florence, Italy (July 2016)
  • The Changing Role of Central Banks in Financial Stability, Northwind Financial Services Forum, Toronto (May 2016)
  • Large Banks and SIFI Supervision, Practising Law Institute (December 2015)
  • Total Loss-Absorbing Capacity, Financial Markets Association, Washington, D.C. (October 2015)
  • Remaining Risks Post-Crisis, International Association of Deposit Insurers, Basel, Switzerland (September 2015)
  • Liquidity in Resolution, TCH/IIF Colloquium on Cross-Border Resolution, New York (November 2015) and London (June 2015)
  • Making Bail-In Operational, Financial Safety Net Conference, Stockholm, Sweden (May 2015)
  • Loss-Absorbing Capacity in Resolution, FSI-IADI Seminar on Bank Resolution, Basel, Switzerland (September 2014)
  • Panel Moderator, Volcker Rule Implementation and Impact, Richmond Fed Credit Markets Symposium (May 2014)
  • Opening Remarks, Institute of International Bankers Seminar on the Section 165 FBO Rule (March 2014)
  • Derivatives Issues in Resolution, TCH/IIF Colloquium on Cross-Border Resolution (December 2013)
  • Bankruptcy not Bailout, SIFMA/TCH Prudential Bank Regulation Conference (June 2013)
  • International Cooperation in Cross-Border Resolution, Bank for International Settlements Forum on Key Regulatory and Supervisory Issues in a Basel III World, Seoul, South Korea (February 2013)
  • Practical Guide to Dodd-Frank Living Wills, New York City Bar (April 2012)
  • Crisis Response and Post-Crisis Reform, Cambridge University (September 2011)
  • Advising Financial Institutions in the New Regulatory Environment, Practising Law Institute (March 2011)
  • Salzburg Global Fellow
  • Advisory Board Member, University of Pennsylvania Institute for Restructuring Studies
  • Banking Law Committee, Association of the Bar of the City of New York