This article was authored by Travis P. Nelson and Mary K. Bessemer. Travis Nelson, resident in the Princeton, NJ and New York, NY offices, is a member of the Firm’s Financial Services Regulatory Group. Travis is formerly with the Enforcement Division of the Office of the Comptroller of the Currency, in Washington, DC. Travis is also Chair of the Banking Law Section of the New Jersey State Bar Association, Editor of the ABA’s Banking Law Committee Journal, adjunct faculty at Villanova University School of Law, and a frequent speaker on financial services issues. Mary Bessemer is a Summer Associate, resident in the Firm’s Princeton, NJ office, and a third-year law student at Seton Hall University Law School.