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James Stevens

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James is the co-leader of the firm’s Financial Services Industry Group. He has significant experience working with clients across the entire financial services sector, regularly working with public and private companies such as banks, neobanks, marketplace lenders, and other fintech and financial services providers and partners.

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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.

On November 5, the Federal Reserve Board announced that it had finalized revisions to its Large Financial Institution (LFI) rating system and the Insurance Supervisory Framework that change when a firm is considered “well managed” and recalibrated the enforcement stance tied to weaker component ratings. Under the new approach, a firm with at least two component ratings of Broadly Meets Expectations or Conditionally Meets Expectations and no more than one Deficient-1 will be deemed “well managed.” The Board also replaces the automatic presumption of an enforcement action for one or more Deficient-1 ratings with a case-by-case determination, while retaining a presumption of formal action for any Deficient-2. The Insurance Supervisory Framework was updated to remove a reference to reputational risk. The changes become effective 60 days after publication in the Federal Register. Governor Michael Barr dissented, warning the rule lowers safeguards and conflicts with statutory “well managed” requirements.

At The Clearing House Annual Conference, Comptroller of the Currency Jonathan Gould outlined an agency-wide strategy to defend and promote federal preemption across the banking system. As reported by Law360, he emphasized pairing court advocacy with public- and policymaker-facing engagement to rebuild political support that he said has eroded over the past 15 years.

Monday, November 10, 2025

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James Stevens, partner and co-leader of Troutman Pepper Locke’s Financial Services Industry Group, will present “Bank Partnerships and Banking‑as‑a‑Service: New Pressure and New Opportunities” at Practising Law Institute’s Banking Law Institute 2025 on Monday, November 10, 2025. This daylong advanced-level CLE program will cover recent developments impacting the…

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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.

Thursday, November 6 • 8:30 a.m. – 3:30 p.m. ET

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Troutman Pepper Locke is proud to sponsor the Community Bankers Association of Georgia’ 2025 Tech Talk – North conference, being held on November 6 in Atlanta, Georgia. James Stevens, co-leader of Troutman Pepper Locke’s Financial Services Industry Group, will be presenting on Regulatory…

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 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…