Thomas C. Baxter, Jr. (bio)
Executive Vice President and General Counsel
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The Legal Group comprises six separate and distinct Functions: Legal, Bank Applications, Compliance, Corporate Secretary's Office (CSO), Federal Reserve Law Enforcement Unit (FRLEU), and Records Management.

The Legal Function is organized into four divisions that correspond roughly to the organizational structure of the Bank. The Function handles the Bank's legal work, including managing the Bank’s involvement in litigation, conducting transactions and formulating general policy, participating in negotiations, as well as drafting and reviewing documents, contracts and correspondence. It consists of the following divisions:

  • The Bank Supervision and Markets Division provides legal support in the areas of bank regulation and supervision, bank and bank holding company applications under authority delegated by the Board of Governors, capital markets (including open market operations), routine and emergency Discount Window liquidity operations, and the domestic and international payments and settlement systems policy and oversight. The Division leader also oversees the New York Fed’s Bank Applications Function.
  • The Corporate Affairs Division provides legal support on issues related to human resources (including diversity, equal employment opportunity, benefits and employment relations), immigration, records management, tax compliance, public information and corporate governance. The division leader also oversees the Corporate Secretary's Office, and works closely with the Bank's Ethics Office on ethics matters and conflict resolutions.
  • Attorneys, investigators and staff in the Enforcement, Litigation, Protection and Investigations Division (ELPI) investigate possible violations of law as well as unsafe and unsound banking practices by banking institutions and institution-affiliated parties and recommend and draft enforcement actions. In addition, ELPI handles all litigation in which the Bank has an interest, and conducts internal investigations involving potential violations of Bank policies. ELPI senior management is also responsible for the Federal Reserve law enforcement officers who ensure the physical security of the Bank's property and employees.
  • The Financial Services, Technology and Contracts Division provides legal support for the Bank's Financial Services Group, Technology Services Group and the Wholesale Product Office. The division also supports the Bank's account relationships with foreign central banks and international organizations as well as handles contract and procurement matters for the Bank.

The Bank Applications Function coordinates, analyzes, evaluates and recommends Federal Reserve action on a variety of proposals by domestic and foreign banking organizations. The Function also contributes to the formulation of Federal Reserve policy relating to these matters. In addition, it educates the banking community (both local and foreign) about U.S. laws and regulations relating to mergers, acquisitions and expansionary activities and assists in proposing amendments to applicable laws and regulations.

The Compliance Function identifies, monitors and remediates legal, regulatory and reputational risks to the New York Fed. It comprises three business areas: the Compliance Department, the Assurance and Advisory Services Unit and the Ethics Office.

  • The Compliance Department identifies compliance risk as well as develops and enhances risk mitigation policies and procedures.
  • The Assurance and Advisory Services Unit independently evaluates the compliance programs of the Bank's business functions, including activities outsourced to independent service providers. It also provides advisory services to senior Bank management and Bank business functions.
  • The Ethics Office provides guidance to employees on conflicts of interest and other Code of Conduct–related issues. It considers waiver requests and serves as a central resource for resolving allegations of violations of policies, laws or regulations, and breaches of accounting, auditing and operational controls.

In addition, the head of Compliance oversees the Records Management Function. This function establishes guidelines and procedures for the management and retention of all Bank records and information as well as supports the efforts of Bank business areas to manage their records in an orderly, efficient and accountable manner.

The Corporate Secretary's Office is responsible for corporate secretarial functions, including coordinating meetings of the Bank's Board of Directors and Management Committee and providing staff assistance to the Directors, the President, and the First Vice President. The CSO also maintains custody of the Bank's seal and assists in the administration of the Freedom of Information Act. The Curatorial Section is responsible for the organization and implementation of the Bank's Centennial Oral History Program. The staff also creates in-house exhibits for the Bank and performs special assignments for senior management. They are responsible for the preservation and research of both the Fed Magazines and photographic collections. The Federal Reserve Law Enforcement Unit provides physical security for Bank property and employees; controls access to Bank premises; provides transportation and safety support for senior Bank officials and visitors; and works with attorneys and investigators to investigate issues involving misconduct within the Bank.

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