Cravath, Swaine & Moore LLP Logo
  • Practices
  • People
  • Careers
  • News & Insights
  • Practices
  • People
  • Careers
  • News & Insights
  • Our Story
  • The Cravath System
  • Diversity & Inclusion
  • Pro Bono
  • Alumni Journal
  • 200.Cravath
This website uses cookies to improve user experience. By using our website you consent to our use of cookies in accordance with our Privacy Notice.

Cravath’s London Office Moves to 100 Cheapside

Read More

People

Will C.
Giles

Of Counsel, Corporate

wgiles@cravath.com
  • Washington, D.C.+1-202-869-7728
    • E-mail
    • Twitter
    • Facebook
    • LinkedIn
  • PDF
  • Vcard
  • Overview
  • Credentials
  • Featured Work
  • News & Insights

Will C. Giles focuses his practice on advising international and domestic banking organizations and other financial institutions on transactional, regulatory, supervisory, enforcement and governance matters.

Mr. Giles has significant experience advising both large financial companies and government agencies regarding bank regulation. From 2010 to 2018, he was an attorney in the Legal Division at the Board of Governors of the Federal Reserve System, rising to the level of Special Counsel. During his time at the Federal Reserve, he advised its principals and senior staff on a host of issues regarding merger and acquisition proposals, change in control matters, implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act and other high priorities for the agency, including rulemakings and other agency efforts regarding resolution planning, qualified financial contracts, total loss absorbing capacity, physical commodities and merchant banking. He also served as a member on the Governance and Controls steering committee of the Large Institution Supervision Coordinating Committee and led the review of a range of novel and complex proposals under the Bank Holding Company Act, Change in Bank Control Act, and Federal Reserve Act. 

Mr. Giles’s practice after leaving the Federal Reserve has focused on advising financial companies and trade organizations regarding a broad range of financial reform, regulatory policy and other regulatory advocacy and compliance matters.

Mr. Giles has been recognized for his work in financial services regulation by The Legal 500 US.

Mr. Giles received a B.S.B.A. from the University of Arkansas in 2004, a J.D. from the University of Virginia School of Law in 2007 and an LL.M. in Banking and Financial Law from the Boston University School of Law in 2010.

Mr. Giles joined Cravath in 2021 and was elected of counsel in 2022.

Mr. Giles has significant experience advising both large financial companies and government agencies regarding bank regulation. From 2010 to 2018, he was an attorney in the Legal Division at the Board of Governors of the Federal Reserve System, rising to the level of Special Counsel. During his time at the Federal Reserve, he advised its principals and senior staff on a host of issues regarding merger and acquisition proposals, change in control matters, implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act and other high priorities for the agency, including rulemakings and other agency efforts regarding resolution planning, qualified financial contracts, total loss absorbing capacity, physical commodities and merchant banking. He also served as a member on the Governance and Controls steering committee of the Large Institution Supervision Coordinating Committee and led the review of a range of novel and complex proposals under the Bank Holding Company Act, Change in Bank Control Act, and Federal Reserve Act. 

Mr. Giles’s practice after leaving the Federal Reserve has focused on advising financial companies and trade organizations regarding a broad range of financial reform, regulatory policy and other regulatory advocacy and compliance matters.

Mr. Giles has been recognized for his work in financial services regulation by The Legal 500 US.

Mr. Giles received a B.S.B.A. from the University of Arkansas in 2004, a J.D. from the University of Virginia School of Law in 2007 and an LL.M. in Banking and Financial Law from the Boston University School of Law in 2010.

Mr. Giles joined Cravath in 2021 and was elected of counsel in 2022.

Education

  • LL.M., 2010, Boston University
  • J.D., 2007, University of Virginia School of Law
  • B.S.B.A., 2004, University of Arkansas, Fayetteville

Admitted In

  • District of Columbia

Rankings

The Legal 500 US

  • Financial Services Regulation (2024)

Deals & Cases

January 22, 2025

CardWorks’s Acquisition of Ally’s Credit Card Business

On January 22, 2025, CardWorks, Inc. (“CardWorks”), a leader in credit and payments, and Ally Financial Inc. (“Ally”), a financial services company with the nation’s largest all‑digital bank and an industry‑leading auto financing business, announced that they have entered into a definitive agreement for CardWorks, and its wholly‑owned bank subsidiary, Merrick Bank, to acquire Ally’s credit card business, including a portfolio of $2.3 billion in credit card receivables with 1.3 million active cardholders as of December 31, 2024. Cravath is representing CardWorks in connection with the transaction.

Deals & Cases

September 26, 2024

Citi’s $25 Billion Private Credit, Direct Lending Program with Apollo

On September 26, 2024, Citigroup Inc. (“Citi”) and Apollo announced they have entered into an exclusive agreement for a subsidiary of Citi and certain affiliates of Apollo to form a landmark $25 billion private credit, direct lending program initially in North America, with the potential to expand to additional geographies. The program will include participation from Mubadala Investment Company as Apollo’s strategic partner as well as Apollo’s subsidiary, Athene, both of which will have the opportunity to join commitments appropriate for their respective mandates. The firms anticipate the program will finance approximately $25 billion of debt opportunities over the next several years, encompassing both corporate and financial sponsor transactions, and maintain the flexibility to significantly expand the size of the program beyond the initial $25 billion. Cravath is representing Citi in connection with the agreement.

Deals & Cases

August 12, 2024

Scotiabank’s $2.8 Billion Acquisition of an Equity Interest in KeyCorp

On August 12, 2024, Scotiabank announced that it has entered into an agreement to acquire an approximate 14.9% pro-forma ownership stake in KeyCorp, a premier U.S. based financial services company, through an issuance of common shares at a price of $17.17 per share. The total cash consideration is approximately $2.8 billion. Cravath is representing Scotiabank in connection with the transaction.

Deals & Cases

August 07, 2024

State Street Corporation’s Offering of Depositary Shares

Cravath represented the underwriters in connection with the $850 million offering of depositary shares representing preferred stock of State Street Corporation, a provider of a broad range of financial products and services to institutional investors worldwide. The transaction closed on July 24, 2024.

Deals & Cases

July 09, 2024

Silvergate’s Settlement Agreements with the Federal Reserve, California Department of Financial Protection and Innovation and Securities and Exchange Commission

On July 1, 2024, Silvergate announced it has agreed to settlements with the Board of Governors of the Federal Reserve System (“Federal Reserve”), the California Department of Financial Protection and Innovation (“DFPI”) and the Securities and Exchange Commission (“SEC”). In a statement, Silvergate noted its decision to liquidate voluntarily and without government assistance in March 2023, and that, as of November 2023, all deposits had been repaid to banking customers, soon after which Silvergate ceased banking operations. The announced settlements, which facilitate the surrender of Silvergate’s bank charter, are part of the Bank’s continued orderly wind down and conclude investigations by the Federal Reserve, DFPI, and SEC. Cravath represented Silvergate in connection with the investigations, resulting settlements, and voluntary liquidation.

Publications

February 07, 2024

Potential FSOC Scrutiny of “Big Tech” Firms

On February 2, 2024, Cravath published a memo for its clients entitled “Potential FSOC Scrutiny of ‘Big Tech’ Firms.”

Publications

November 22, 2023

FSOC’s New Guidance on Nonbank “SIFI” Designations

On November 20, 2023, Cravath published an executive summary‑style alert for its clients, with insights and reflections on the procedural guidance that the Financial Stability Oversight Council (“FSOC”) recently finalized for designating nonbank financial companies as “systemically important financial institutions” (“SIFIs”).

Publications

July 21, 2023

Will Giles Authors Article for Law360 on Notable Developments in New York Financial Services Law

Cravath of counsel Will C. Giles authored an article entitled “NY Banking Brief: All The Notable Compliance Updates In Q2,” which was published to the website of Law360 on July 13, 2023. The article outlines the most significant legislative and regulatory developments in New York financial services law in the second quarter of 2023, including those related to bank closures, the release of a proposed bill to regulate digital asset activities and the passage of legislation that would empower the New York State Department of Financial Services to regulate fees related to consumer bank accounts.

Publications

May 02, 2023

FSOC Proposes New Guidance on Nonbank “SIFI” Designation Process

On May 1, 2023, Cravath prepared a memo for its clients entitled “FSOC Proposes New Guidance on Nonbank ‘SIFI’ Designation Process.” The memo examines the Financial Stability Oversight Council’s recent proposals concerning its procedures for designating nonbank financial companies as “systemically important financial institutions” and its framework for assessing financial stability risks. 

Publications

January 31, 2023

Summary of Federal Reserve Board Policy Statement on Section 9(13) of the Federal Reserve Act and Related Developments

On January 30, 2023, Cravath distributed a memo for its clients entitled “Summary of Federal Reserve Board Policy Statement on Section 9(13) of the Federal Reserve Act and Related Developments.” The memo examines key takeaways from recent policy pronouncements regarding cryptoassets made by the Federal Reserve Board (“FRB”) and the White House. In that regard, the memo outlines the FRB’s recent policy statement, which effectively prohibits FRB‑regulated banks from engaging in most cryptoasset activities as principal.  Please click here to read the memo.

Will C. Giles focuses his practice on advising international and domestic banking organizations and other financial institutions on transactional, regulatory, supervisory, enforcement and governance matters.

Mr. Giles has significant experience advising both large financial companies and government agencies regarding bank regulation. From 2010 to 2018, he was an attorney in the Legal Division at the Board of Governors of the Federal Reserve System, rising to the level of Special Counsel. During his time at the Federal Reserve, he advised its principals and senior staff on a host of issues regarding merger and acquisition proposals, change in control matters, implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act and other high priorities for the agency, including rulemakings and other agency efforts regarding resolution planning, qualified financial contracts, total loss absorbing capacity, physical commodities and merchant banking. He also served as a member on the Governance and Controls steering committee of the Large Institution Supervision Coordinating Committee and led the review of a range of novel and complex proposals under the Bank Holding Company Act, Change in Bank Control Act, and Federal Reserve Act. 

Mr. Giles’s practice after leaving the Federal Reserve has focused on advising financial companies and trade organizations regarding a broad range of financial reform, regulatory policy and other regulatory advocacy and compliance matters.

Mr. Giles has been recognized for his work in financial services regulation by The Legal 500 US.

Mr. Giles received a B.S.B.A. from the University of Arkansas in 2004, a J.D. from the University of Virginia School of Law in 2007 and an LL.M. in Banking and Financial Law from the Boston University School of Law in 2010.

Mr. Giles joined Cravath in 2021 and was elected of counsel in 2022.

Mr. Giles has significant experience advising both large financial companies and government agencies regarding bank regulation. From 2010 to 2018, he was an attorney in the Legal Division at the Board of Governors of the Federal Reserve System, rising to the level of Special Counsel. During his time at the Federal Reserve, he advised its principals and senior staff on a host of issues regarding merger and acquisition proposals, change in control matters, implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act and other high priorities for the agency, including rulemakings and other agency efforts regarding resolution planning, qualified financial contracts, total loss absorbing capacity, physical commodities and merchant banking. He also served as a member on the Governance and Controls steering committee of the Large Institution Supervision Coordinating Committee and led the review of a range of novel and complex proposals under the Bank Holding Company Act, Change in Bank Control Act, and Federal Reserve Act. 

Mr. Giles’s practice after leaving the Federal Reserve has focused on advising financial companies and trade organizations regarding a broad range of financial reform, regulatory policy and other regulatory advocacy and compliance matters.

Mr. Giles has been recognized for his work in financial services regulation by The Legal 500 US.

Mr. Giles received a B.S.B.A. from the University of Arkansas in 2004, a J.D. from the University of Virginia School of Law in 2007 and an LL.M. in Banking and Financial Law from the Boston University School of Law in 2010.

Mr. Giles joined Cravath in 2021 and was elected of counsel in 2022.

Education

  • LL.M., 2010, Boston University
  • J.D., 2007, University of Virginia School of Law
  • B.S.B.A., 2004, University of Arkansas, Fayetteville

Admitted In

  • District of Columbia

Rankings

The Legal 500 US

  • Financial Services Regulation (2024)

Deals & Cases

January 22, 2025

CardWorks’s Acquisition of Ally’s Credit Card Business

On January 22, 2025, CardWorks, Inc. (“CardWorks”), a leader in credit and payments, and Ally Financial Inc. (“Ally”), a financial services company with the nation’s largest all‑digital bank and an industry‑leading auto financing business, announced that they have entered into a definitive agreement for CardWorks, and its wholly‑owned bank subsidiary, Merrick Bank, to acquire Ally’s credit card business, including a portfolio of $2.3 billion in credit card receivables with 1.3 million active cardholders as of December 31, 2024. Cravath is representing CardWorks in connection with the transaction.

Deals & Cases

September 26, 2024

Citi’s $25 Billion Private Credit, Direct Lending Program with Apollo

On September 26, 2024, Citigroup Inc. (“Citi”) and Apollo announced they have entered into an exclusive agreement for a subsidiary of Citi and certain affiliates of Apollo to form a landmark $25 billion private credit, direct lending program initially in North America, with the potential to expand to additional geographies. The program will include participation from Mubadala Investment Company as Apollo’s strategic partner as well as Apollo’s subsidiary, Athene, both of which will have the opportunity to join commitments appropriate for their respective mandates. The firms anticipate the program will finance approximately $25 billion of debt opportunities over the next several years, encompassing both corporate and financial sponsor transactions, and maintain the flexibility to significantly expand the size of the program beyond the initial $25 billion. Cravath is representing Citi in connection with the agreement.

Deals & Cases

August 12, 2024

Scotiabank’s $2.8 Billion Acquisition of an Equity Interest in KeyCorp

On August 12, 2024, Scotiabank announced that it has entered into an agreement to acquire an approximate 14.9% pro-forma ownership stake in KeyCorp, a premier U.S. based financial services company, through an issuance of common shares at a price of $17.17 per share. The total cash consideration is approximately $2.8 billion. Cravath is representing Scotiabank in connection with the transaction.

Deals & Cases

August 07, 2024

State Street Corporation’s Offering of Depositary Shares

Cravath represented the underwriters in connection with the $850 million offering of depositary shares representing preferred stock of State Street Corporation, a provider of a broad range of financial products and services to institutional investors worldwide. The transaction closed on July 24, 2024.

Deals & Cases

July 09, 2024

Silvergate’s Settlement Agreements with the Federal Reserve, California Department of Financial Protection and Innovation and Securities and Exchange Commission

On July 1, 2024, Silvergate announced it has agreed to settlements with the Board of Governors of the Federal Reserve System (“Federal Reserve”), the California Department of Financial Protection and Innovation (“DFPI”) and the Securities and Exchange Commission (“SEC”). In a statement, Silvergate noted its decision to liquidate voluntarily and without government assistance in March 2023, and that, as of November 2023, all deposits had been repaid to banking customers, soon after which Silvergate ceased banking operations. The announced settlements, which facilitate the surrender of Silvergate’s bank charter, are part of the Bank’s continued orderly wind down and conclude investigations by the Federal Reserve, DFPI, and SEC. Cravath represented Silvergate in connection with the investigations, resulting settlements, and voluntary liquidation.

Publications

February 07, 2024

Potential FSOC Scrutiny of “Big Tech” Firms

On February 2, 2024, Cravath published a memo for its clients entitled “Potential FSOC Scrutiny of ‘Big Tech’ Firms.”

Publications

November 22, 2023

FSOC’s New Guidance on Nonbank “SIFI” Designations

On November 20, 2023, Cravath published an executive summary‑style alert for its clients, with insights and reflections on the procedural guidance that the Financial Stability Oversight Council (“FSOC”) recently finalized for designating nonbank financial companies as “systemically important financial institutions” (“SIFIs”).

Publications

July 21, 2023

Will Giles Authors Article for Law360 on Notable Developments in New York Financial Services Law

Cravath of counsel Will C. Giles authored an article entitled “NY Banking Brief: All The Notable Compliance Updates In Q2,” which was published to the website of Law360 on July 13, 2023. The article outlines the most significant legislative and regulatory developments in New York financial services law in the second quarter of 2023, including those related to bank closures, the release of a proposed bill to regulate digital asset activities and the passage of legislation that would empower the New York State Department of Financial Services to regulate fees related to consumer bank accounts.

Publications

May 02, 2023

FSOC Proposes New Guidance on Nonbank “SIFI” Designation Process

On May 1, 2023, Cravath prepared a memo for its clients entitled “FSOC Proposes New Guidance on Nonbank ‘SIFI’ Designation Process.” The memo examines the Financial Stability Oversight Council’s recent proposals concerning its procedures for designating nonbank financial companies as “systemically important financial institutions” and its framework for assessing financial stability risks. 

Publications

January 31, 2023

Summary of Federal Reserve Board Policy Statement on Section 9(13) of the Federal Reserve Act and Related Developments

On January 30, 2023, Cravath distributed a memo for its clients entitled “Summary of Federal Reserve Board Policy Statement on Section 9(13) of the Federal Reserve Act and Related Developments.” The memo examines key takeaways from recent policy pronouncements regarding cryptoassets made by the Federal Reserve Board (“FRB”) and the White House. In that regard, the memo outlines the FRB’s recent policy statement, which effectively prohibits FRB‑regulated banks from engaging in most cryptoasset activities as principal.  Please click here to read the memo.

Cravath Bicentennial

Celebrating 200 years of partnership. In 2019, we celebrated our bicentennial. Our history mirrors that of our nation. Integral to our story is our culture.

Explore

Cravath, Swaine & Moore LLP Logo
  • CONTACT US
  • OUR STORY
  • ALUMNI PORTAL
  • DISCLAIMERS & NOTICES

Attorney Advertising. ©2025 Cravath, Swaine & Moore LLP.