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Carlin McCrory

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A seasoned regulatory and compliance attorney, Carlin brings extensive experience representing financial institutions, fintechs, lenders, payment processors, neobanks, virtual currency companies, and mortgage servicers.

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On December 16, the Federal Reserve Board issued a Request for Information on a new special‑purpose “Payment Account” prototype, which is essentially a stripped‑down Federal Reserve Bank account designed for institutions focused on payments innovation. The goal with this specialized or “skinny” access is to give legally eligible, payments‑centric institutions a more predictable and lower‑risk path to access key Federal Reserve payment services, without changing who is legally eligible for Federal Reserve master accounts.

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November 12 – 14, 2025

Members of Troutman Pepper Locke’s Financial Services Industry Group are set to speak at the upcoming Third Party Payment Processor’s Annual Conference, “Solving the Payment Puzzle.” This event offers attendees valuable insights into the latest developments in payments and compliance.

On October 8, the Office of the Comptroller of the Currency (OCC), in collaboration with the Financial Crimes Enforcement Network (FinCEN), the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the National Credit Union Administration, released a set of frequently asked questions (FAQs) concerning Suspicious Activity Reports (SARs). These FAQs aim to clarify regulatory requirements related to SARs, assisting financial institutions in fulfilling their compliance obligations while optimizing resources for activities that provide the greatest value to law enforcement and other government users of Bank Secrecy Act (BSA) reporting.

On July 18, America’s Credit Unions sent a letter to the Honorable Kyle Hauptman, Chairman of the National Credit Union Administration (NCUA), urging the agency to initiate rulemaking that would allow credit unions to take custody of digital assets for their members. This request comes in the wake of the recently enacted “Guiding and Establishing National Innovation for U.S. Stablecoins Act of 2025” (GENIUS Act), which provides a comprehensive federal framework for the regulation of payment stablecoins.

Today, the Office of the Comptroller of the Currency (OCC), alongside the Federal Deposit Insurance Corporation (FDIC) and the National Credit Union Administration (NCUA) (collectively, the agencies), with concurrence from the Financial Crimes Enforcement Network (FinCEN), issued an order granting an exemption from a specific requirement of the Customer Identification Program (CIP) Rule under § 326 of the USA PATRIOT Act. This exemption allows financial institutions to use alternative methods to collect Taxpayer Identification Number (TIN), (e.g., Social Security Number, individual taxpayer identification number, or employer identification number) information from third-party sources rather than directly from customers. The order applies to accounts at all entities supervised by the agencies.

On March 17, the Office of the Comptroller of the Currency (OCC) announced that it has granted conditional approval for SmartBiz Loans to transform the business model of CenTrust Bank, N.A., located in Northbrook, Illinois. This approval follows SmartBiz Loans’ acquisition of CenTrust Bank, N.A., which has since been renamed SmartBiz Bank, N.A. The approval allows SmartBiz Bank, N.A. to expand its small business lending activities on a nationwide scale.

On January 14, Patriot Bank, N.A. entered into an agreement with the Office of the Comptroller of the Currency (OCC) to address and rectify several unsafe or unsound practices and violations of law. This agreement follows the bank’s reported loss of nearly $27 million for the quarter ending September 30, 2024.

This week, President Trump designated National Credit Union Administration (NCUA) Vice Chairman Kyle Hauptman as the thirteenth Chairman of the NCUA Board. Hauptman succeeds Todd Harper as NCUA Chairman. In the press release announcing his appointment, Chairman Hauptman said, “I am deeply honored that President Trump has asked me to serve as Chairman of NCUA. I look forward to leading the agency’s dedicated professionals and working with my Board colleagues to create a regulatory structure that promotes growth, opportunity, and innovation within the credit union system.”

On January 10, the Consumer Financial Protection Bureau (Bureau) issued a notice of proposed interpretive rule (Proposed Rule). The deadline for comments is March 31, 2025. The Proposed Rule would apply the Electronic Fund Transfer Act (EFTA)—which protects consumers against errors and fraud—to new types of digital payment mechanisms, including stablecoins and other digital currencies.