Jenny Small
PHONE: 720.488.5427
EMAIL: jsmall@os.law
Jenny Small is a partner at Otteson Shapiro with a focus on bank transactions, enforcement, regulatory compliance, financial technology and mergers and acquisitions.
With more than a decade of regulatory experience at the Office of the Comptroller of the Currency (OCC), she developed deep expertise in payment systems, licensing and banking regulations, and providing guidance on innovative banking structures and novel financial products. She worked extensively with large and community banks, thrifts and organizers to navigate regulatory expectations and requirements for new charters, changes-in-bank control, substantial asset plan changes, conversions and liquidations.
Small also brings a regulatory perspective to assist clients with strategizing and addressing risk. At the OCC, she advised examiners on prudential regulations and led investigations into bank fraud. She negotiated and executed enforcement actions related to fraud, capital and liquidity issues, corporate governance, and risk management systems.
Small has been a panelist on anti-money laundering at the Independent Bankers of Colorado BSA Mile High Summit; regulatory investigations and enforcement actions at the OCC, FRB, FDIC, and NCUAInteragency Enforcement Conference; and tribal banking at the Native American Finance Officers Association Conference. She has instructed the OCC’s bank examination staff on critical regulatory topics, and has provided training through continuing legal education and new attorney programs. She has also represented the United States, training foreign bank regulators on early detection and risk mitigation tools for problem banks.
REPRESENTATIVE CASES
Lead counsel reviewing application, assessing novel blockchain technology and legal requirements. Developed regulatory strategies, translated complex technology into actionable legal analysis and aligned application review with OCC priorities.
Lead analyst in the merger of Discover Bank into Capital One, National Association, one of the highest-profile bank transactions at the OCC. Addressed complex issues and interagency coordination. Strategized with internal business units to leverage expertise and briefed senior leaders.
RECOGNITIONS
Special Act Award, U.S. Treasury, for contributions to 2023 market disruptions
Special Act Award, U.S. Treasury, for contributions to 2023 diversity, equity, and inclusion
Chief Counsel’s Award, Office of the Comptroller of the Currency, 2022
Comptroller’s Special Act Award, 2022
OCC Western District Customer Service Award, 2020