Alison Epperson

Managing Associate

New York

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Alison JW Epperson helps clients navigate high-stakes white collar criminal investigations and enforcement matters, with a focus on the Foreign Corrupt Practices Act and anti-corruption compliance. 

Alison represents individuals and corporations in a broad range of white collar criminal defense, anti-corruption, regulatory and trade matters across the globe with a focus on the Foreign Corrupt Practices Act (FCPA) and other anti-corruption laws and regulations. Alison's practice involves conducting internal investigations, representing clients in matters before the U.S. Department of Justice and U.S. Securities & Exchange Commission, and enhancing corporate compliance programs. Alison has extensive experience responding to subpoenas and information requests from government entities and has trial and litigation experience in multiple federal district courts. She has also helped clients navigate shareholder books and records inspection demands and shareholder derivative lawsuits. Alison has represented companies around the world in the oil and gas, education, pharmaceutical, blockchain, technology, and financial industries.

Alison's practice also includes online safety issues, including advising companies on compliance with online safety-related obligations and best practices in the US and conducting online safety compliance risk assessments, especially as it relates to user safety on internet dating platforms. Alison's experience includes representing clients in connection with criminal and civil investigations conducted by state attorneys general related to state online safety legislation. 

Alison remains committed to serving her community through pro bono representation and has experience in reproductive rights cases and policies, immigration and asylum matters, death penalty cases, policing and racial justice cases and policies, and a range of other constitutional issues. Alison has represented clients on civil and criminal matters in federal court, including a domestic violence survivor in a Hague Convention proceeding. Most recently, Alison helped achieve a meaningful settlement on behalf of the family of a man killed by police officers in Greenville, Mississippi after convincing the district court to deny qualified immunity for the officers involved.

Prior to joining Orrick, Alison graduated from Case Western Reserve University School of Law. In addition, while pursuing her undergraduate degree from Centre College, Alison worked on Capitol Hill in Washington, D.C., specifically in the Health, Education, Labor, and Pensions committee. In 2016, Alison co-founded the non-profit, CTE Hope, an organization dedicated to addressing the issues and research of traumatic brain injures and chronic traumatic encephalopathy.

Posts by: Alison Epperson

Federal Reserve Announces Plan to Develop a New Round-the-Clock Real-Time Payment and Settlement Service to Support Faster Payments


On August 5, the Federal Reserve Board announced that the Federal Reserve Banks will develop a new round-the-clock real-time payment and settlement service, called the FedNow℠ Service, to support faster payments in the United States. The rapid evolution of technology presents a pivotal opportunity for the Federal Reserve and the payment industry to modernize the nation’s payment system and establish a safe and efficient foundation for the future. The Federal Reserve believes faster payment services, which enable the near-instantaneous transfer of funds day and night, weekend and weekdays, have the potential to become widely used and to yield economic benefits for individuals and businesses by providing them with more flexibility to manage their money and make time-sensitive payments. Release.

HUD Announces Agency Efforts to Reduce Risk From Cash-Out Refinance Lending


On August 1, the U.S. Department of Housing and Urban Development (HUD) announced joint policy actions designed to reduce risk associated with cash-out refinance lending. The changes preserve homeowners’ ability to convert home equity to cash via a government-sponsored mortgage but also improves the risk profile of HUD’s housing finance programs. To address these concerns, the Federal Housing Administration (FHA) will lower its maximum loan-to-value (LTV) requirements for cash-out refinance transactions from 85 percent to 80 percent. This policy change will be effective for loans with case numbers assigned on or after September 1, 2019 and aligns with the maximum cash-out LTV allowed by the Government Sponsored Enterprises (GSEs). Release.

White House and HUD Publish Opportunity Zone Implementation Plan


On April 17, the White House Opportunity and Revitalization Council (Council) published its Implementation Plan, a detailed work plan for how the Council chaired by U.S. Department of Housing and Urban Development (HUD) Secretary Ben Carson will accomplish the goals specified in Executive Order 13583 of December 12, 2018. The Implementation Plan explains the various subcommittees of the Council, as well as describes the strategy to implement administrative reforms and initiatives that will target, streamline, coordinate and optimize federal resources in economically distressed communities, including Opportunity Zones. Release.

Rating Agency Developments


On February 22, Fitch released the following report: What Investors Want to Know: ESG Relevance Scores (Marking the Intersection of Credit Risk and ESG Risks). Report.

On February 22, DBRS released the following methodology: Master European Residential Mortgage-Backed Securities Rating Methodology and Jurisdictional Addenda. Methodology.

On February 22, Moody’s released the following methodology: US RMBS Surveillance Methodology. Methodology.

On February 22, Moody’s released the following methodology: Moody’s Approach to Rating Securitizations Backed by Non-Performing and RE-Performing Loans. Methodology.

On February 21, Moody’s released the following methodology: Moody’s Approach to Rating Transaction Backed by Portfolios of Hedge Fund Investments. Methodology.

On February 21, KBRA published a report entitled: Structured Finance: Subprime Auto Loan ABS: Does Seasoning Matter? Report.

On February 21, DBRS released the following methodology: Rating Pooled Aircraft Lease Securitizations. Methodology.

FDIC-Insured Institutions Report Net Income of $59.1 Billion in Fourth Quarter 2018


Commercial banks and savings institutions insured by the Federal Deposit Insurance Corporation (FDIC) reported aggregate net income of $59.1 billion in the fourth quarter of 2018, up $33.8 billion (133.4 percent) from a year ago. The improvement in net income was led by higher net operating revenue and lower income tax expenses. Financial results for the fourth quarter of 2018 are included in the FDIC’s latest Quarterly Banking Profile released February 21. Release.

FHA Expands Pilot Program to Accelerate Financing of Low-Income Housing Tax Credit Projects


On February 21, U.S. Housing and Urban Development (HUD) Secretary Ben Carson announced a significant expansion of a Federal Housing Administration (FHA) pilot program that streamlines FHA mortgage insurance applications for affordable housing developments that have equity from the sale of Low-Income Housing Tax Credit (LIHTC) Program, the nation’s primary source of affordable housing production. Release.

SEC Modifies Timing for Filing of Non-Public Form N-PORT Data


On February 27, the Securities Exchange Commission (SEC) modified the submission deadlines for registered investment companies filing non-public monthly reports on Form N-PORT. Form N-PORT is a new form for reporting both public and non-public fund portfolio holdings to the Commission in a structured data format. As a result of today’s changes, rather than filing non-public monthly reports with the Commission within 30 days after each month-end, funds will be required to maintain the relevant information in their records and file all three monthly reports with the Commission no later than 60 days after the end of each fiscal quarter. Release.

Bureau Announces System for Prepaid Issuers to Submit Account Agreements


On February 27, the Consumer Financial Protection Bureau (Bureau) announced a streamlined electronic submission system for prepaid account issuers to submit their account agreements to the Bureau. Prepaid issuers can register for the system now before the April 1 effective date of the Bureau’s prepaid rule. Release.