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David assists clients with a variety of transactional needs, including mergers and acquisitions and other general corporate matters. He focuses his practice on structured finance and securitization matters. David represents the corporate trust departments of financial institutions in their capacities as corporate trustee, collateral administrator, collateral agent, paying agent, custodian, securities intermediary, and other service provider capacities. He has representative experience in collateralized loan obligation transactions, warehouse facilities, and loan financing transactions.

The Office of the Comptroller of the Currency (OCC) has issued a Notice of Proposed Rulemaking aimed at clarifying the permissible activities of national trust banks. The proposal seeks to amend chartering regulations to explicitly state that national trust companies may engage in nonfiduciary activities, such as asset custody, without being required to obtain a full-service national bank charter. However, the proposed rule does not address what specific nonfiduciary activities are permissible, nor does it indicate whether a national trust company must engage in a minimum level of fiduciary activities.

The Report authored by the Presidential Working Group on Digital Assets Markets (PWG), titled “Strengthening American Leadership in Digital Financial Technology,” along with the accompanying fact sheet, outlines several key objectives aimed at positioning the U.S. as a leader in digital asset markets. Among its objectives are reinforcing the role of the U.S. dollar, modernizing Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT) rules for the digital assets ecosystem, and ensuring fairness and predictability by establishing clear regulatory oversight.

We are pleased to share with you our latest publication, “Navigating Change: First 100 Days under the Trump Administration,” authored by our Digital Assets + Blockchain team. This retrospective examines the pivotal developments in the digital assets industry during the initial phase of the Trump administration.