Brian Callanan — profile dossier

Pandemic-program role: Treasury's top lawyer (General Counsel) for the CARES Act legal architecture: the legal structuring of the ~$500B Title IV / Exchange Stabilization Fund (ESF) lending facilities, the §4003 airline and national-security loan program, and the interim final rules standing up the Paycheck Protection Program (PPP).
Institution · office: Treasury · Office of the General Counsel · Type: political (PAS)
Tenure (relief-relevant): Senate-confirmed General Counsel Sept 18, 2019 – January 2021 (Deputy GC from 2017; Acting GC before confirmation). CARES Act enacted Mar 27, 2020.¹²³

The job (role mechanics)

Level / appointment: PAS: Presidentially appointed, Senate-confirmed; Executive Schedule Level IV (EX-IV). Nomination PN794 (116th Congress); Senate Finance hearing July 24, 2019; confirmed Sept 18, 2019 by a 55–39 vote (Record Vote 291).²⁴⁵
Reports to: Secretary of the Treasury (Steven T. Mnuchin during the relief-relevant period).¹
Core responsibility: Chief legal officer of Treasury; head of the Treasury Legal Division (a bureau of lawyers across the Department and its component bureaus, ~2,000 attorneys per his later bio); "provides legal and policy advice to the Secretary and other senior Treasury officials."¹³
Pay: Executive Schedule Level IV = $172,500 (2021), per the OPM 2021-EX salary table (the official EX-IV rate; a separate statutory pay freeze set the EX-IV payable rate for certain senior political officials at $158,500 through Jan 1, 2022).⁶
Expectations / mandate: Run Treasury's legal function; in the pandemic, structure and clear the legal authority for Title IV ESF deployment (airline/national-security loans plus equity backstops for Federal Reserve §13(3) facilities) and the Treasury/SBA PPP rulemaking; manage Treasury's litigation docket and relationships with oversight bodies (SIGPR, the Congressional Oversight Commission, GAO, Treasury OIG).³⁷
Tenure norm: Serves at the pleasure of the President (political appointee). His actual dates: confirmed GC Sept 18, 2019; General Counsel through January 2021.²⁸

Who they are

Brian R. Callanan is an appellate/regulatory litigator and government-investigations lawyer who became Treasury's General Counsel. Listed as "of New Jersey" on his nomination. Member of the Council on Foreign Relations; trustee of the Antonin Scalia Law School Foundation; Visiting Research Fellow at Georgetown's business school.²³

Education

Claremont McKenna College, undergraduate degree.¹
Harvard Law School, J.D.¹
Clerkship: Judge A. Raymond Randolph, U.S. Court of Appeals for the D.C. Circuit.¹

Career before

U.S. Senate: Staff Director and General Counsel of the Permanent Subcommittee on Investigations (PSI); senior advisor to Sen. Rob Portman. Led several congressional investigations.¹³
Private practice in Washington, D.C.: appellate and regulatory litigation and government investigations.¹³
U.S. Treasury: joined as Deputy General Counsel in 2017; served as Acting General Counsel "during a critical transition period" before his 2019 Senate confirmation as General Counsel.¹

Role in the pandemic relief programs

As Treasury's General Counsel through 2020, Callanan was the Department's senior lawyer over the CARES Act relief architecture. His own later bio states he was "a key advisor on major domestic and national security initiatives, including the implementation of historic economic rescue programs in response to COVID-19."³ He was supported by two Deputy General Counsels, Brian P. Morrissey Jr. and James Y. Stern, both listed in the 2020 Plum Book as non-career SES under his office. Specifically:

Title IV / ESF facilities (~$500B): Treasury's legal structuring of the Coronavirus Economic Stabilization Act (CARES Act §4003) lending: direct loans to airlines and businesses critical to national security, plus the ESF equity that backstopped the Federal Reserve's §13(3) facilities (PMCCF, SMCCF, MLF, Main Street, TALF). The General Counsel's office cleared the legal authority for these structures.⁷⁹
Airline / national-security loan program (§4003(b)(1)–(3)): On Mar 30, 2020 Treasury published the "Procedures and Minimum Requirements for Loans to Air Carriers and Eligible Businesses and National Security Businesses under Division A, Title IV, Subtitle A of the CARES Act," alongside payroll-support guidelines under Subtitle B: the legal terms (warrants/financial-instrument requirements, executive-compensation and buyback limits, conflicts-of-interest bars) that the Legal Division shaped.⁷
PPP rulemaking: Treasury (with SBA) issued the PPP interim final rules during his tenure as the Department's chief lawyer; no document we have attributes the Department's PPP legal sign-off to him personally.³

He managed Treasury's litigation docket and its relationships with the multiple oversight bodies created for the relief programs.³

Documents written or signed

Senate Finance Committee opening statement at his confirmation hearing, July 24, 2019 (testimony on file with the Committee).¹⁰⁴
Treasury Legal Division clearance of the Mar 30, 2020 CARES Act Title IV loan procedures and airline payroll-support guidelines (Treasury press release SM960). Note: ultimate signatory authority for ESF transactions rested with the Secretary; the GC's role is legal structuring and clearance, which is typically not separately signed.⁷
Not personally bylined in public PPP/§4003 Federal Register notices.

Career after / where they are now

Liberty Strategic Capital: partner and general counsel of Steven T. Mnuchin's private-equity firm (approximately $3 billion in assets under management, per his own bio); member of its Investment Committee.³¹¹
Board seats via Liberty: director of Flagstar Bank (appointed to the board of Flagstar Financial, Inc. in Dec 2024, following Liberty's ~$1.05B investment) and director of Zimperium, Inc. (mobile cybersecurity).³¹²
TD Bank: appointed U.S. General Counsel (Executive Vice President), announced Oct 16, 2025, effective Dec 1, 2025; "TD Bank, America's Most Convenient Bank."¹³³
Honors: received Treasury's Alexander Hamilton Award (the Department's highest honor) in recognition of his ~four years of service.³
Current status (2025–2026): EVP and U.S. General Counsel, TD Bank (since Dec 1, 2025); also a listed speaker at the Milken Institute's Future of Finance 2026.¹³³

Sources held in this archive

Original source documents and archived captures

Sources (first-party)

Treasury official bio, "Brian Callanan," U.S. Department of the Treasury — Treasury official bio, "Brian Callanan," U.S. Department of the Treasury — archived snapshot (original: home.treasury.gov · stored capture) (archived snapshot: Treasury official bio, "Brian Callanan," U.S. Department of the Treasury — archived snapshot (original: web.archive.org · stored capture)). ↩
U.S. Senate nomination record PN794, 116th Congress — "Brian Callanan, of New Jersey, to be General Counsel for the Department of the Treasury"; actions incl. hearing 07/24/2019, reported 07/31/2019, confirmed 09/18/2019 by 55–39 (Record Vote 291) — U.S. Senate nomination record PN794, 116th Congress — "Brian Callanan, of New Jersey, to be General Counsel for the D... (original: congress.gov · stored capture). Roll-call corroboration: U.S. Senate nomination record PN794, 116th Congress — "Brian Callanan, of New Jersey, to be General Counsel for the D... (original: govtrack.us · stored capture). ↩
Milken Institute speaker bio, "Brian Callanan," Future of Finance 2026 (self-supplied bio) — confirms TD Bank EVP/GC (Dec 2025); Liberty Strategic Capital SMD & GC; Flagstar and Zimperium boards; ~2,000 Treasury lawyers; COVID-19 economic-rescue programs; Alexander Hamilton Award; CFR / Scalia Law School Foundation / Georgetown; education and clerkship — Milken Institute speaker bio, "Brian Callanan," Future of Finance 2026 self-supplied bio — confirms TD Bank EVP/GC De... (original: milkeninstitute.org · stored capture). ↩
Hearing transcript: "Nominations of Brent James McIntosh … Brian Callanan, to be General Counsel, Department of the Treasury …," Senate Finance Committee, July 24, 2019 (CHRG-116shrg44390) — Hearing transcript: "Nominations of Brent James McIntosh … Brian Callanan, to be General Counsel, Department of the T... (original: govinfo.gov · stored capture). ↩
United States Government Policy and Supporting Positions (Plum Book) 2020, GPO — Treasury section lists the General Counsel as a PAS / Executive Level IV position — United States Government Policy and Supporting Positions, 2020 — Committee on Oversight and Reform (original: govinfo.gov · stored capture). ↩
OPM Salary Table No. 2021-EX, "Rates of Basic Pay for the Executive Schedule (EX), Effective January 2021" — Level IV = $172,500 (pay-freeze payable EX-IV = $158,500) — Ex Pdf 6009Adaafdb86580 (original: opm.gov · stored capture). ↩
Treasury press release SM960 (Mar 30, 2020), "Treasury Releases Guidance on Payroll Support to Aid Airline Industry Employees, and on Loans to Airline Industry and Businesses Critical to National Security, Pursuant to CARES Act" (links the Subtitle A loan procedures and Subtitle B payroll-support guidelines) — Treasury press release SM960 Mar 30, 2020, "Treasury Releases Guidance on Payroll Support to Aid Airline Industry Emp... (original: home.treasury.gov · stored capture). ↩
LegiStorm biography, "Brian R. Callanan" — lists "U.S. Department of the Treasury, Office of the General Counsel (Sept. 2019–Jan. 2021), General Counsel" (secondary; used only to corroborate end-of-tenure dating) — LegiStorm biography, "Brian R. Callanan" — lists "U.S. Department of the Treasury, Office of the General Counsel Sept... (original: legistorm.com · stored capture). ↩
Congressional Research Service, "Treasury and Federal Reserve Financial Assistance in Title IV of the CARES Act (P.L. 116-136)," R46329 (structure of the ~$500B ESF/Title IV program) — Congressional Research Service, "Treasury and Federal Reserve Financial Assistance in Title IV of the CARES Act P.L.... (original: congress.gov · stored capture). ↩
Senate Finance Committee, Callanan opening statement, July 24, 2019 (PDF) — 07242019 Callanan 3401f3806a6a56b6 (original: finance.senate.gov · stored capture). ↩
Bloomberg Law, "Mnuchin Private Equity Firm Loads Up on Former Treasury Lawyers" (secondary; lists Callanan among Liberty Strategic Capital hires) — Bloomberg Law, "Mnuchin Private Equity Firm Loads Up on Former Treasury Lawyers" secondary, for the Cooper & Kirk → L... (original: news.bloomberglaw.com · stored capture). ↩
Flagstar Financial, Inc. news release, "Flagstar Financial, Inc. Appoints Brian Callanan to Board of Directors" (Dec 2024; following Liberty's ~$1.05B investment) — Flagstar Financial, Inc. news release, "Flagstar Financial, Inc. Appoints Brian Callanan to Board of Directors" Dec 2... (original: prnewswire.com · stored capture). ↩
TD Stories (TD Bank) news release, "TD Bank Announces Key Executive Appointments in U.S." (dated Oct 17, 2025; Mount Laurel, N.J., Oct 16, 2025) — Brian Callanan appointed U.S. General Counsel effective Dec 1, 2025 — TD Stories TD Bank news release, "TD Bank Announces Key Executive Appointments in U.S." dated Oct 17, 2025; Mount Lau... (original: stories.td.com · stored capture). ↩