Nazareth started as an associate at Davis Polk & Wardwell in 1981. She left the firm five years later to work in the securities industry. In 1998, she joined the SEC as a senior counsel to then-chairman Arthur Levitt. One year later she became director of the Division of Market Regulation, a post she would hold until she became commissioner in 2005. She returned to Davis Polk in 2008 and currently serves as the managing partner of the Washington office.
Legal Times sat down with Nazareth to discuss the current state of the Washington office, the Dodd-Frank rule and—well, because it’s summer-like out there right now—hot dogs.
Your return to the firm marked a reboot of the Washington office. What is the history behind that?
We have about 26 lawyers in the D.C. office, and I would say that the firm was very committed to revitalizing the Davis Polk Washington office with my return. We had operated for a time here without a partner in Washington. Davis Polk decided that it would be strategic to grow the Washington office with a focus on government and regulatory issues, including financial services. I returned to the firm in 2008 and was the first partner here in several years. Since that time, we have brought in several partners with government experience.
What is keeping the office busy these days?
There are a lot of things going on in the financial institutions group. Partner Susan Ervin and I do a lot of the trading and markets work. Susan has a background at both the CFTC (U.S. Commodity Futures Trading Commission) and the SEC. We are doing a lot of the Dodd-Frank work with a current focus on Title 7 which is the swaps provisions. It's really the implementation of all the rules around swaps trading. And on the litigation side, we have a host of regulatory litigation and regulatory actions that our attorneys are focused on.
What is the plan for growth?
We've been largely organic. We are not interested in growing for growth's sake. On the other hand, we brought in John Reynolds who does a lot of the OFAC (Office of Foreign Assets Control) and CFIUS (Committee on Foreign Investment in the United States) work. We also have an interest in expanding our antitrust practice. Mike Sohn joined Davis Polk from Arnold & Porter, where he was the managing partner. He has been a wonderful addition to our office. We do continue to have an interest in growing on the antitrust side.
How does the Washington office fit into the larger scale of the firm?
What we do in Washington is an adjunct to what we do firm wide, but particularly in New York. What has made the Washington office particularly successful is that we operate with New York as if we are one office. It's a relatively short corridor. I work on a number of things that involve New York clients and travel back and forth frequently. I think that can also account for some of the success that we have enjoyed. We are not standalone and therefore we have all the benefits of the economies of scale by operating as a unit. We bring this Washington perspective and the ability to represent clients in government related issues, but it is part of the larger finance focus that we have as a firm.
What effect has Dodd-Frank had on the firm's practice?
It's had a very big impact on part of our practice. I would say that in the financial institutions group, the two most significant areas that we are working on relate to the swaps regulatory area and the representation of a great number of banks on their living wills. Those are both very much Dodd-Frank driven engagements.
I think we did distinguish ourselves as a firm of being on the forefront of thought leadership of how Dodd-Frank was going to affect our clients and in attempting to explain in a straightforward and clear manner as possible what the changes meant to our clients.
Now we're focused on the derivatives while the bank regulators are back to working through the comments on Volker. Volker will be back and we played a very large role in advising many of our clients both domestically and internationally.
What keeps you busy outside of the practice of law?
Family is first and foremost what I spend my time on. I have a daughter graduating from high school and a son graduating from college. They have been a large focus of my free time. I do also serve on some boards, but generally not for profit. I'm on the board of Brown University, the National Cathedral School, the Urban Institute and Bishop Walker School.
You're a native Rhode Islander. I have a weakness for this hot dog place in Providence.
New York System hot dogs, where they line them up on their arm…I can't believe you know New York System hot dogs. There is nothing more delicious than those hot dogs. I grew up eating New York System hot dogs. It's because they put the meat and the onion and the spicy mustard. It's to die for.
You sound like a bit of a hot dog connoisseur.
I hadn't thought about it in years and I actually don't eat that many hot dogs, but there is no hot dog like those New York System hot dogs.
This is part of a series of Q&A sessions Legal Times is conducting with D.C.-based law firm managing partners. Photo by The National Law Journal's Diego M. Radzinschi.