Davis Polk represented ICICI Bank Limited (“ICICI” or the “Bank”) in connection with an investigation by the U.S. Securities and Exchange Commission into the Bank’s loan impairment provisions under U.S. GAAP.  The investigation lasted approximately four years.  On October 27, 2020, ICICI announced that the SEC informed the Bank that it had concluded its investigation and does not intend to bring an enforcement action against the Bank.

ICICI is the largest private sector bank in India and the second-largest bank in India in terms of total assets. ICICI has over 5,324 branches in India and branches and representative offices throughout the world, including in the United States, Canada, Europe and Asia.  ICICI is listed on the Bombay Stock Exchange, the National Stock Exchange of India and the New York Stock Exchange.

The Davis Polk team included partners Margaret E. Tahyar and Paul J. Nathanson, senior counsel Linda Chatman Thomsen, counsel Nino Stamatovic, and associates Lindsay Schare, Andrew Rohrkemper, Tyson Dean Kennedy, Michelle C. Musielewicz and Stephanie R. Hansen, and former associate Matthew Weinberg.  Members of the Davis Polk team are based in the New York, Washington DC and Northern California offices.     

The Law Offices of Panag & Babu, led by partner Sherbir Panag, acted as Indian counsel for ICICI in connection with the SEC investigation.

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