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It had been two days since U.S. lawmakers negotiated all night to finish rules that would reshape the business of Wall Street. The 20-hour session left legislators, aides, lobbyists and regulators exhausted. Almost no one had a grip on all the details.

Then Annette Nazareth stepped in. That Sunday morning, she e-mailed a dozen Securities and Exchange Commission officials about the bill that would become the 2,300-page Dodd-Frank Act.

Nazareth, herself a former SEC commissioner, represents the biggest banks and securities firms as a partner in the Washington office of Davis Polk & Wardwell LLP. She attached an annotated copy of the measure to her June 27, 2010, e-mail, marking changes made during the wee hours. It could be an invaluable tool for an agency hard-pressed to analyze the bill on a tight deadline.

“In case you would find it helpful,” Nazareth wrote to the group, many of them ex-colleagues. Two hours later, SEC Chairman Mary Schapiro responded: “Thanks. We have our work cut out for us.”

Nazareth’s e-mails to Schapiro and then-SEC General Counsel and Senior Policy Director David Becker, obtained through a Freedom of Information Act request filed by Bloomberg News, demonstrate how lobbyists and lawyers draw on bonds they formed in government service to gain access for clients, and how they work to maintain those ties.

It’s “a real advantage” to send a familiar face into the agency, said Adam Pritchard, a University of Michigan law professor and ex-SEC lawyer. “If I’m a client, I’m very pleased. I’m willing to pay top dollar for that.”

She told Becker the prospect of a consumer finance protection agency made her “feel ill” and that she’d asked Sifma, the Wall Street trade group, to “trash” a proposal for an investor advocacy office at the SEC.

Officials routinely leave federal agencies, Congress and the White House to work for the industries they once supervised. While that path is well-trod and legal -- with some time restrictions -- it still provokes handwringing in Washington. Nazareth’s communications provide an inside look at what happens when the revolving door spins.

Nazareth, 56, declined to discuss specific e-mails. She said that people like herself who have worked for both sides are valuable because they can “better translate to their clients” what the SEC is trying to achieve.

“It’s unfortunate where we are in an environment now where everybody thinks that is nefarious,” Nazareth said.

Nazareth and her colleagues at Davis Polk played a central role as the financial industry shaped its Dodd-Frank priorities, helping write more than 80 comment letters to regulators. The firm’s clients, including Sifma, JPMorgan Chase & Co. (JPM) and Bank of America Corp., targeted rules such as the so-called Volcker ban on proprietary trading, arguing it could create excessive burdens on banks, choke off business and hurt the economy.

In May, Nazareth was named as the top woman lawyer in financial regulation at the Americas Women in Business Law awards in New York. Public disclosures from the SEC also underline her clout. In 2009 and 2010, she attended 11 meetings with Schapiro -- twice as many as any single competitor in the law and lobbying business -- according to the chairman’s appointment calendar. Since Dodd-Frank was enacted, Nazareth has taken executives from firms including Goldman Sachs Group Inc. (GS) and Credit Suisse to the SEC, agency memos show.

Lynn Turner, a former SEC chief accountant who is critical of the banks’ agenda, said that Nazareth is “at the top of that list of influential attorneys” who have access to regulators as former SEC officials.

In her e-mails, Nazareth blended the personal and professional. For instance, she sympathized with Schapiro over a “frustrating” New York Times article in one message, and in another offered to sell the SEC a Davis Polk Web product “at an appropriate government rate.”

The overlap was sometimes evident in Nazareth’s salutations, which varied from “Dear SEC friends” and “Dear Mary and David” to “Hello All.” On March 10, 2010, for example, she wrote to “Chairman Schapiro” asking if she’d take a meeting with Credit Suisse “to discuss the SEC’s concept release on equity market structure.” After Schapiro agreed, Nazareth wrote back: “Fantastic, Mary!”

Early in the Dodd-Frank debate, in November 2009, Nazareth forwarded a summary of a Senate proposal to Becker, who noted that the actual text ran to 1,100 pages. “More nap time for me,” he wrote.

That prompted Nazareth to ask, “Yea, but what about me? No rest for the outside counsel.”

After a month had gone by without any e-mails, Nazareth contacted Becker at 5:46 a.m. on Aug. 13.

“You never call. You never write. Do you have any time for lunch?” she wrote. They met the following week at an eatery in Washington’s Union Station, which is connected to the SEC offices.

The e-mails include matters beyond Dodd-Frank.

In February 2011, Nazareth forwarded Schapiro an exchange with New York Times reporter Edward Wyatt, who was writing an SEC story. Wyatt asked Nazareth to let him use a laudatory comment she had given him about Schapiro.

Nazareth asked Wyatt to include the name of her law firm. She objected to his identifying her solely as someone who “represents clients before the commission,” saying it might imply she was praising the chairman to benefit clients. “That is not the case,” Nazareth wrote. “I believe what I said.”

When she sent the e-mails to Schapiro two minutes later, Nazareth wrote: “The following seems to indicate that at least part of the piece will be positive.”

Schapiro replied: “Thanks so much. I have fingers (and toes) crossed.”

Becker publicly addressed the revolving door at an Oct. 8, 2010, Cleveland conference on securities regulation, where he sat next to Nazareth on the panel. The two discussed the event in advance, the e-mails show. Becker’s remarks were prompted by suggestions from participants that the agency’s enforcers tend to go easy on firms represented by former SEC lawyers.

“When you’re an SEC alum, particularly someone who’s high- level, certainly your clients think you have a certain degree of influence,” Becker told the conference at Case Western Reserve University’s law school. http://www.bloomberg.com/news/2012-09-05/top-bank-lawyer-s-e-mails-sho
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