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Greg leverages his broad experience and pragmatic approach, bringing a wealth of knowledge, business insight and practical problem-solving skills to efficiently manage transactions and advise clients in an evolving legal landscape. He combines his corporate and transactional experience with a robust knowledge of bank regulatory issues to provide valued legal solutions for financial institutions, financial technology companies and other businesses. Greg often works closely with clients to design and implement internal policies and procedures and contractual safeguards in commercial arrangements in connection with corporate and regulatory requirements and risk management best practices.

WASHINGTON, D.C. – Troutman Pepper Locke advised ODNB Financial Corporation, the holding company for Old Dominion National Bank, a locally owned community bank serving markets including the Washington, D.C. metro area, in the completion of a private placement of a $25 million 7.25% fixed-to-floating rate subordinated note due 2035 to a subsidiary of EJF Capital, LLC, a locally-based global institutional asset management firm specializing in financials. For more information, see the press release.

On December 16, the Federal Deposit Insurance Corporation (FDIC) proposed a new rule that would create a formal, bank‑centric process for issuing payment stablecoins. The rule is designed to implement the Guiding and Establishing National Innovation for U.S. Stablecoins Act (the GENIUS Act) and would apply to FDIC‑supervised institutions, state nonmember banks and state savings associations, that want to issue payment stablecoins through a subsidiary. With this proposed rule, the FDIC is seeking to “evaluate the safety and soundness of an applicant’s proposed activities based on consideration of statutory factors and support the responsible growth and use of digital assets and related technologies while minimizing the regulatory burden on applicants.”

On December 17, the Office of the Comptroller of the Currency (OCC) proposed new guidance that would significantly streamline how community banks elect to be evaluated under the Community Reinvestment Act (CRA) by providing a simplified strategic plan form. Framed as part of Comptroller Gould’s broader initiative to reduce regulatory burden on community banks, the proposal would make the strategic plan option more accessible, more predictable, and less resource‑intensive for smaller institutions.

Federal banking regulators previewed near-term rulemaking plans that will shape the fintech landscape. The Federal Deposit Insurance Corporation (FDIC) expects to issue a stablecoin licensing proposal “before the end of the year,” and the FDIC reiterated that “a deposit is a deposit” even when tokenized. Separately, the Federal Reserve is targeting the fourth quarter of 2026 for operational rollout of “skinny” master accounts to widen access to payment rails for eligible depository institutions.

On October 29, the Federal Reserve’s Division of Supervision and Regulation issued a Statement of Supervisory Operating Principles that formalizes Vice Chair for Supervision Miki Bowman’s August direction to reset how the Fed supervises banks. The goal of this action is to strengthen supervision by focusing on identifying and acting early on the most important risks to safety and soundness, using proportionate, timely measures. This represents a significant change from prior practice, moving away from process-heavy supervision and toward judgment-driven oversight.

WASHINGTON, D.C. – Troutman Pepper Locke advised Piper Sandler & Co., a leading investment bank, as sole placement agent in Univest Financial Corporation’s $50 million private placement of fixed-to-floating rate subordinated notes. For more information, see the press release.

On October 7, the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) unveiled two significant notices of proposed rulemaking (NPRs) designed to reshape the regulatory landscape for financial institutions. The first NPR aims to eliminate the use of reputation risk as a basis for regulatory actions, thereby reducing subjectivity in supervisory programs. This proposed rulemaking responds to concerns expressed in Executive Order 14331, Guaranteeing Fair Banking for All Americans, that the use of reputation risk can be a pretext for restricting law-abiding individuals’ and businesses’ access to financial services on the basis of political or religious beliefs or lawful business activities. The second NPR seeks to establish a clear definition of “unsafe or unsound practice” and revise the framework for issuing Matters Requiring Attention (MRAs) and other supervisory communications, with a focus on material financial risks. As of now, “unsafe or unsound practice” is not defined in the statute.

On October 6, the Office of the Comptroller of the Currency (OCC) announced a series of significant actions aimed at reducing the regulatory burden on community banks. These initiatives are part of the OCC’s ongoing efforts to tailor its regulatory and supervisory frameworks, thereby promoting economic growth and allowing community banks to better serve their

WASHINGTON, D.C. – Troutman Pepper Locke served as counsel to Simmons First National Corporation (Simmons), an Arkansas corporation and the bank holding company for Simmons Bank, an Arkansas state-chartered bank, in connection with Simmons’ underwritten public offering of 18,653,000 shares of its Class A common stock (including 2,433,000 shares pursuant to the underwriters’ option to purchase additional shares of common stock in the offering). The public offering price of shares of common stock sold in the offering was $18.50 per share, and the underwriters agreed to purchase the shares from Simmons pursuant to the underwriting agreement at a price of $17.575 per share.