WASHINGTON — Amy Friend, the former chief counsel of the Senate Banking Committee who helped draft the Dodd-Frank financial reform law, is rejoining the Office of the Comptroller of the Currency as its top lawyer.

Friend will succeed Julie Williams, who was forced out by Comptroller Tom Curry last year after serving 19 years as the agency's chief counsel.

The move is effectively a trade between the OCC and Promontory Financial Group, where Friend has been working for the past two years as a managing director. The consulting firm announced last week that Williams would start Monday as head of its domestic advisory practice. Friend, in turn, is expected to start shortly at the OCC.

Friend also previously worked for Williams at the OCC, serving as assistant chief counsel until January 2008, when she was hired by then-Senate Banking Chairman Chris Dodd as the panel's top lawyer.

In that capacity, Friend was instrumental in helping to draft the legislation creating the Troubled Asset Relief Program and Dodd-Frank.

That does not mean she has always been pleased with the implementation of the reform law, however.

She was one of several outside observers who raised concerns about federal regulators' draft of the so-called Volcker Rule, saying in March that the ban on proprietary trading, with its myriad of exceptions, had ended up as "an exercise in line-drawing."

She recommended regulators adopt a simpler approach.

"It seems to make sense to dial it back, use the metrics and the conformance period to test these things and let the regulators refine their understanding," Friend said. "If they have the benefit of time to collect these metrics, analyze what they mean and work with the industry to try to figure out their utility in a very iterative way, that would be prudent. It feels to me like the process needs to develop more organically."

Importantly, regulators have yet to finalize the Volcker Rule, although top agency heads have signaled that they are largely on the same page on how to proceed and expect a final regulation shortly.

Friend also comes to the job with a host of other experience. Prior to working at the OCC, she also served as minority general counsel for the former House Banking Committee (now Financial Services Committee) and general counsel to the House subcommittee on consumer affairs and coinage.

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