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Saule Omarova

Economics & Finance

Saule Omarova

Earle Hepburn Professor of Law, University of Pennsylvania Law School

Saule Omarova is the Earle Hepburn Professor of Law at The University of Pennsylvania.

She was previously Beth and Marc Goldberg Professor of Law at Cornell University School of Law.

Professor Omarova specializes in the regulation of financial institutions, banking law, international finance, and corporate finance.

In 2021, she was nominated to serve as Comptroller of The Currency by President Biden.

Before joining Cornell Law School in 2014, she was the George R. Ward Associate Professor of Law at the University of North Carolina School of Law.

Prior to joining academia, Professor Omarova practiced law in the Financial Institutions Group of Davis, Polk, & Wardwell, a premier New York law firm, where she specialized in a wide variety of corporate transactions and advisory work in the area of financial regulation. In 2006-2007, she served at the U.S. Department of the Treasury as a Special Advisor for Regulatory Policy to the Under Secretary for Domestic Finance.

Born: Kazakhstan.

Cornell University Law School:

Beth and Marc Goldberg Professor of Law, June 2019 – present Professor of Law and Public Affairs, July 2014 – June 2019 Courses: Corporate Finance, Financial Institutions, Securities Regulation, Issues in Financial Regulation

Director, Jack Clarke Institute for the Study and Practice of Business Law, Program on the Law and Regulation of Financial Institutions and Markets

University of Toronto School of Law, Toronto: Distinguished Visiting Professor, January 2023; Course: Digitization of Money and Finance: A Systemic Perspective.

Cornell Paris Summer Institute, Paris, France: Courses: Global Financial Markets (July 2015; July 2016).

University of North Carolina at Chapel Hill, School of Law: George R. Ward Associate Professor of Law (with tenure), July 2013 – June 2014 Assistant Professor, July 2007 – June 2013; Courses: Banking Law; International Banking and Finance; Global Financial Markets; Corporate Finance; International Business Transactions.

Georgetown University Law Center: Visiting Professor, Fall 2012; Courses: Corporate Finance; Financial Regulation Reform.

University of Augsburg, Faculty of Law: Visiting Professor in the Augsburg Summer Program in European and International Economic Law, June-July 2010; Courses: Introduction to the U.S. Financial Sector Regulation; Joint Seminar on Capital Markets Law and Legal Methodology.

Université Jean Moulin Lyon, Faculty of Law: Visiting Professor at the Institute of Comparative Law, March-April 2012; Courses: Introduction to U.S. Administrative Law.

U.S. Department of the Treasury: Special Advisor for Regulatory Policy to the Under Secretary, Domestic Finance, July 2006 – July 2007.

Davis Polk & Wardwell, New York, NY: Associate, Financial Institutions Group, October 2001 – July 2006.

Baker & McKenzie, Attorneys At Law, Chicago, IL: Part-Time Law Clerk, January – April 2000; Summer Associate, May - August 1999.

Central Asia Institute, Johns Hopkins University School for Advanced International Studies: Visiting Research Fellow, January - July 1998.

Center for International Security and Arms Control, Stanford University: Visiting MacArthur Scholar, September 1995 - May 1996.

Moscow State University, Department of Philosophy: Teaching Assistant, September 1990 – May 1991.

Education
PhD Political Science, University of Wisconsin Madison · JD Law, Northwestern University School of Law · Diploma Philosophy, Moscow State University
Topics
Law · Finance · Regulation of Financial Institutions · Banking Law · International Finance · Corporate Finance

In the Encyclopedia1

Talks & video6

  • • Build Back Better: Investing in Equitable and Affordable Housing Infrastructure, U.S. House of Representatives Committee on Financial Services (virtual), April 14, 20212021
  • • Facebook’s Libra Project, Briefing for Members of the U.S. House of Representatives Committee on Financial Services, Washington, D.C., October 16, 20192019
  • • Fintech: Examining Digitization, Data, and Technology, Testimony before the U.S. Senate Committee on Banking, Housing, and Urban Affairs, Washington, D.C., September 18, 20182018
  • • Fostering Economic Growth: Midsized, Regional and Large Institution Perspective, Testimony before the U.S. Senate Committee on Banking, Housing, and Urban Affairs, Washington, D.C., June 15, 20172017
  • • Financial Holding Companies’ Activities in Physical Commodity Markets: Key Issues from the Perspective of U.S. Banking Law and Policy, Testimony before the U.S. Senate Committee on Homeland Security and Governmental Affairs, Permanent Subcommittee on Investigations, Washington, D.C., November 21, 20142014
  • • Large U.S. Banking Organizations’ Activities in Physical Commodity and Energy Markets: Legal and Policy Considerations, Testimony before the U.S. Senate Banking Committee’s Subcommittee on Financial Institutions and Consumer Protection, Washington, D.C., July 23, 20132013

Selected publications58

  1. 2023• Industrial Policy Requires Public, Not Just Private, Equity (with Todd Tucker), DEMOCRACY JOURNAL (March 27, 2023)
  2. 2023• Money and Banking Through the Lens of the “Networks, Platforms, and Utilities” Law: Preliminary Thoughts, Yale Journal on Regulation Symposium, Notice & Comment (Jan. 25, 2023)
  3. 2022• State Capitalism in the United States: Development Finance State (with Robert C. Hockett), in THE OXFORD HANDBOOK OF STATE CAPITALISM AND THE FIRM, ED. BY MIKE WRIGHT ET.AL. (Oxford University Press, 2022), pp.623-639
  4. 2022• The National Investment Authority: An Institutional Blueprint, Berggruen Institute White Paper (March 24, 2022)
  5. 2021• The “Franchise” View of the Corporation: Purpose, Personality, Public Policy, in RESEARCH HANDBOOK ON CORPORATE PURPOSE AND PERSONHOOD, ED. BY ELIZABETH POLLMAN AND ROBERT B. THOMPSON (Elgar 2021), pp. 201-221
  6. 2021• Fintech and the Limits of Financial Regulation: A Systemic Perspective, in ROUTLEDGE HANDBOOK ON FINANCIAL TECHNOLOGY AND LAW, ED. BY IRIS H-Y CHIU & GUDULA DEIPENBROCK (Routledge 2021), pp. 44-61
  7. 2021• The People’s Ledger: How to Democratize Money and Finance the Economy, 74 VAND. L. REV. 1231-1300 (2021)
  8. 2021• Millions of Low-Income People Are Locked Out of The Financial System. More Big Tech Monopoly Power Is Not The Answer, The Appeal: The Lab Report (May 6, 2021)
  9. 2020• Technology v. Technocracy: Fintech as a Regulatory Challenge, 6 J. FIN. REG. 75-124 (2020)
  10. 2020• Dealing with Disruption: Emerging Approaches to Fintech Regulation, 61 WASH. U. J. L. & POL’Y 25-53 (2020)
  11. 2020• What Kind of Finance Should There Be? 83 L. & CONTEMP. PROB.195-218 (2020)
  12. 2020• The Climate Case for a National Investment Authority, Data for Progress Report (Aug. 5, 2020)
  13. 2020• A National Investment Authority: Financing America’s Future, The Justice Collaborative Institute and Data for Progress Report (July 9, 2020),
  14. 2020• Why We Need A National Investment Authority (2020)
  15. 2020• The Other Half of the FedAccounts Plan: What Happens on the Asset Side of the Fed’s Ledger? Just Money Roundtable, “Public Money” (Harvard Law School) (November 19, 2020)
  16. 2020• Crises, Bailouts, and the Case for a National Investment Authority, Just Money Roundtable, “Money in the Time of Coronavirus” (Harvard Law School) (April 1, 2020)
  17. 2020• What Do Banks Intermediate? (with Robert C. Hockett), Just Money Roundtable “Banking: Intermediation or Money Creation?” (Harvard Law School) (February 5, 2020)
  18. 2019• New Tech v. New Deal: Fintech as a Systemic Phenomenon, 36 YALE J. REG. 735-793 (2019)
  19. 2019• The “Too Big To Fail” Problem, 103 MINN. L. REV. 2495-2541 (2019)
  20. 2019• Rethinking “Too Big To Fail,” Harvard Law School Bankruptcy Roundtable (March 19, 2019)
  21. 2019• Central Banking and Finance –The Franchise View (with Robert C. Hockett), Law & Political Economy (March 13, 2019)
  22. 2019• Deconstructing “Too Big To Fail:” A New Take on an Old Problem, NYU Compliance & Enforcement (February 26, 2019)
  23. 2019• The ‘Too Big To Fail” Problem, Oxford Business Law Blog (February 25, 2019)
  24. 2018• Central Banks, Systemic Risk, and Financial Sector Structural Reform, in RESEARCH HANDBOOK ON CENTRAL BANKING, ED. BY ROSA LASTRA AND PETER CONTI-BROWN (Elgar, 2018), pp. 487-507
  25. 2018• Ethical Finance as a Systemic Challenge: Risk, Culture, and Structure, 27 CORNELL J. L. & PUB. POL. 797-839 (2018)
  26. 2018• Private Wealth and Public Goods: A Case for a National Investment Authority (with Robert C. Hockett), 43 J. CORP. L. 437-491 (2018)
  27. 2018• White Paper: A National Investment Authority (with Robert C. Hockett) (2018)
  28. 2018• How to Make Finance Ethically Sound: Make It Structurally Sound, Oxford Business Law Blog (September 3, 2018)
  29. 2018• Fintech as a Systemic Phenomenon, Harvard Law School Forum on Corporate Governance and Financial Regulation (August. 28, 2018)
  30. 2018• Ethical Finance as a Systemic Challenge: Risk, Culture, and Structure, The FinReg Blog (August 14, 2018)
  31. 2018• Central Banks, Systemic Risk, and Financial Sector Structural Reform, Oxford Business Law Blog (February 9, 2018)
  32. 2017• The Finance Franchise (with Robert C. Hockett), 102 CORNELL L. REV. 1143-1218 (2017)
  33. 2017• Bank Governance and Systemic Stability: The “Golden Share” Approach, 68 ALA. L. REV. 1029- 1070 (2017)
  34. 2017Bank Governance and Systemic Stability, Harvard Law School Forum on Corporate Governance and Financial Regulation (May 26, 2017), https://corpgov.law.harvard.edu/2017/05/26/bank-governanceand-systemic-stability-the-golden-share-approach/
  35. 2016• Systemically Significant Prices (with Robert C. Hockett), 2 J. FIN. REG. 1-20 (2016)
  36. 2016• “Special,” Vestigial, or Visionary? What Bank Regulation Tells Us About the Corporation – and Vice Versa (with Robert C. Hockett), 39 SEATTLE. U. L. REV. 453-500 (2016)
  37. 2016• Public Actors in Private Markets: Toward a Developmental Finance State (with Robert C. Hockett), 93 WASH. U. L. REV. 103-175 (2015). Republished in the Corporate Practice Commentator (2016)
  38. 2016• Challenging the Financial Intermediation Myth (with Robert C. Hockett), The Columbia Law School (CLS) Blue Sky Blog (October 17, 2016)
  39. 2015• Bank Regulation as Vestigial Corporate Regulation (with Robert C. Hockett), The Columbia Law School (CLS) Blue Sky Blog (October 12, 2015)
  40. 2015• Toward “Deep” Financial Reform: The U.S. as a Developmental Finance State (with Robert C. Hockett), The Columbia Law School (CLS) Blue Sky Blog (April 10, 2015)
  41. 2014• One Step Forward, Two Steps Back? The Institutional Structure of U.S. Financial Services Regulation After the Crisis of 2008, in INSTITUTIONAL STRUCTURE OF FINANCIAL REGULATION: THEORIES AND INTERNATIONAL EXPERIENCES, ED. BY ROBIN HUI HUANG & DIRK SCHOENMAKER (Routledge, 2014), pp. 137-165
  42. 2014• “Private” Means to “Public” Ends: Governments as Market Actors (with Robert C. Hockett), 15 THEORETICAL INQUIRIES IN LAW 53-76 (2014)
  43. 2013• Beyond Finance: Permissible Commercial Activities of U.S. Financial Holding Companies, in AN UNFINISHED MISSION: MAKING WALL STREET WORK FOR US, A REPORT BY AMERICANS FOR FINANCIAL REFORM & THE ROOSEVELT INSTITUTE, ED. BY MIKE KONCZAL & MARCUS STANLEY (2013), pp. 110-25
  44. 2013• The Merchants of Wall Street: Banking, Commerce, and Commodities, 98 MINN. L. REV. 265-355 (2013)
  45. 2013• From Reaction to Prevention: Product Approval as a Model of Derivatives Regulation, 3 HARV. BUS. L. REV. ONLINE 98 (2013)
  46. 2013• That Which We Call a Bank: Revisiting the History of Bank Holding Company Regulation in the United States (with Margaret E. Tahyar), 31 REV. BANKING & FIN. L. 113-198 (2011-12). Republished in the Corporate Practice Commentator (2012-2013)
  47. 2013• Taking Gatekeeping Seriously: Financial Product Approval as a Form of Systemic Risk Regulation, The Columbia Law School (CLS) Blue Sky Blog (June 12, 2013),
  48. 2012• The United States: ‘With Freedom and Liberty for All’ (Saule T. Omarova, Cynthia Williams, Lisa Lamkin Broome, and John Conley), in BANKING SYSTEMS IN THE CRISIS: THE FACES OF LIBERAL CAPITALISM, ED. BY SUZANNE J. KONZELMANN & MARC FOVARGUE-DAVIES (Routledge, 2012), pp. 57-79
  49. 2012• License To Deal: Mandatory Approval of Complex Financial Products, 90 WASH. U. L. REV. 63- 140 (2012)
  50. 2012• Bankers, Bureaucrats, and Guardians: Toward Tripartism In Financial Services Regulation, 37 J. CORP. L. 621-674 (2012)
  51. 2011• From Gramm-Leach-Bliley to Dodd-Frank: The Unfulfilled Promise of Section 23A of the Federal Reserve Act, 89 N. C. L. REV. 1683-1776 (2011)
  52. 2011• Wall Street as Community of Fate: Toward Financial Industry Self-Regulation, 159 U. PA. L. REV. 411-492 (2011)
  53. 2011• The Dodd-Frank Act: A New Deal for a New Age?, 15 N.C. BANKING INST. 83-98 (2011)
  54. 2010• Rethinking the Future of Self-Regulation in the Financial Industry, 35 BROOKLYN J. INT’L L. 665- 706 (2010) (invited symposium contribution)
  55. 2009• The Quiet Metamorphosis: How Derivatives Changed the “Business of Banking,” 63 MIAMI L. REV. 1041-1109 (2009)
  56. 2009• Risks, Rules, and Institutions: A Process for Reforming Financial Regulation (with Adam Feibelman), 39 U. MEM. L. REV. 881-930 (2009) (invited symposium contribution)
  57. 2009• The New Crisis for the New Century: Some Observations on the “Big-Picture” Lessons of the Global Financial Crisis of 2008, 13 N.C. BANKING INST. 157-165 (2009)
  58. • Banking and Antitrust (with Graham S. Steele), 133 YALE L.J. (forthcoming)

Positions & affiliations25

  • University of Pennsylvania Law School
  • Cornell University Law School
  • University of North Carolina School of Law
  • • Faculty Advisor, Cornell Law Review, 2020 - present
  • • Member of the Advisory Board, Cornell Research Academy of Development Law and Economics (CRADLE), 2017 - present
  • • Member of the Committee on International Monetary Law of the International Law Association (MOCOMILA), 2021 - present
  • • Member of the Advisory Board, Open Markets Institute (Washington, D.C.), 2017 - present
  • • Member of the Editorial Board, JOURNAL OF INTERNATIONAL ECONOMIC LAW (Oxford University Press), 2015–2022
  • • Contributing Editor, CORPORATE LAW JOTWELL (THE JOURNAL OF THING WE LIKE (LOTS)), 2012- 2022
  • • Member, Cornell University Appeals Panel, 2016-2021
  • • Member, Cornell Law School Appointments Committee, 2015-2016; 2017-2018; 2020-2021
  • • Member, Cornell Law School Administrative Committee, 2019-2021; 2022-2023
  • • Member, Cornell Law School Admissions Committee, 2021-2022
  • • Member, Cornell Law School Academic Programs & Planning Committee, 2016-2019
  • • Member, Cornell Law School Alumni in Academia Committee, 2018-2021
  • • Member, Cornell Law School Business Law Committee, 2014-2015
  • • Chair, AALS Section on Financial Institutions and Consumer Financial Services, 2013-14
  • • Chair-Elect, AALS Section on Financial Institutions and Consumer Financial Services, 2011-12
  • • Executive Committee Member, AALS Section on Financial Institutions and Consumer Financial Services, 2009-2011
  • • Member, UNC-Chapel Hill School of Law Speakers Committee, 2013-2014
  • • Member, UNC-Chapel Hill School of Law Appointments Committee, 2009-2010
  • • Member, UNC-Chapel Hill School of Law International Programs Committee, 2007–2013
  • • Member, Faculty Steering Committee, UNC-Chapel Hill Graduate Certificate in International Development, 2008-2014
  • • Member, Executive Committee, UNC Center for European Studies, 2009 - 2014
  • • Faculty Advisor, The North Carolina Journal of International Law and Commercial Regulation, 2007-2014

Credentials & fellowships1

  • New York State Bar

Honours & awards6

  • • Distinguished Visitor, Law & Political Economy (LPE) Program, Yale Law School, New Haven, CT (November 2022)
  • • Cornell Law School Convocation Speaker (May 12, 2018), selected by the Class of 2018
  • • Dean’s Distinguished Scholar in Residence, Washington University School of Law, St. Louis, MO (October 2016)
  • • Winner of the 1st prize in the Junior Faculty Scholarship Competition at the Inaugural Junior Faculty Business and Financial Law Workshop (April 1-2, 2011), organized by the Center for 3 Law, Economics, and Finance (C-LEAF), George Washington University School of Law, Washington, D.C.
  • • Winner of the 2010 James H. Chadbourn Award for Excellence in Scholarship, recognizing a member of the faculty of the UNC School of Law for publication of an academic article that shows great scholarly achievement, creativity and insight, and/or the promise of critical impact. The Chadbourn Award is given annually by the Dean upon a recommendation by the faculty selection committee.
  • • A draft of The Merchants of Wall Street: Banking, Commerce, and Commodities was selected for presentation at the 2013 Harvard/Stanford/Yale Junior Faculty Forum at Yale law School.