James Stevens, a co-leader of Troutman Pepper Locke’s Financial Services Industry Group, was quoted in the August 22, 2025 Bank Director article, “How One CEO Built a Team to Fix His Bank.”
BaaS is more prone to scrutiny because so much has been outsourced to a third party, says James Stevens, a partner
On August 15, the Federal Reserve Board announced a significant shift in its approach to supervising novel activities within banking organizations. The Board decided to sunset its Novel Activities Supervision Program, which was initially established to enhance oversight of activities related to crypto-assets, distributed ledger technology (DLT), and complex partnerships with non-banks. This program, launched in 2023, aimed to address the unique risks posed by these innovative financial activities, ensuring they were appropriately managed within the banking sector.
On July 16, the Federal Reserve Board, the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, the federal banking agencies) jointly published a proposed rule to rescind the 2023 Community Reinvestment Act (CRA) final rule. This proposal aims to revert to the CRA framework that was in effect prior to the 2023 amendments, with certain technical updates. This decision follows ongoing litigation in the Fifth Circuit, where banking trade associations challenged the 2023 rule, alleging regulatory overreach.
On July 14, the Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System (the Board), and the Federal Deposit Insurance Corporation (FDIC) jointly issued a statement addressing the safekeeping of crypto-assets by banking organizations on behalf of their customers. This announcement clarifies how existing laws, regulations, and risk management principles apply to the safekeeping of crypto-assets by banks and does not create any new supervisory expectations. Importantly, the federal banking regulators clearly signal that banks can serve as custodians of digital assets including storing cryptographic keys.
On July 14, the Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System (the Board), and the Federal Deposit Insurance Corporation (FDIC) jointly issued a statement addressing the safekeeping of crypto-assets by banking organizations on behalf of their customers. This announcement clarifies how existing laws, regulations, and risk management principles apply to the safekeeping of crypto-assets by banks and does not create any new supervisory expectations. Importantly, the federal banking regulators clearly signal that banks can serve as custodians of digital assets including storing cryptographic keys.
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 June 17, the U.S. Senate voted 68-30 to pass S.1582, the Guiding and Establishing National Innovation for U.S. Stablecoins Act, known as the GENIUS Act (the Act). This represents a landmark effort by the U.S. Congress to establish a comprehensive federal framework for the regulation of payment stablecoins. Passed with bipartisan support in the Senate, the Act aims to provide regulatory clarity, enhance consumer protection, and safeguard national security in the rapidly growing stablecoin sector.
On June 16, the Federal Deposit Insurance Corporation (FDIC), the Federal Reserve Board, and the Office of the Comptroller of the Currency (OCC) issued a joint request for public comment on potential ways to address payments fraud, with a particular emphasis on check fraud.
Register Here
June 13 – 15, 2025
Troutman Pepper Locke is proud to sponsor the Georgia Bankers Association’s 2025 Annual Meeting. James Stevens will be a featured speaker, providing an update on board strategy. The event will take place at The Omni Boston Hotel at Seaport in Boston, MA, from June 13-15, 2025.
May 7 – 8, 2025
James Stevens presented on The Regulatory Environment Around the Convergence of Banking and Fintechs at the Payments & Banking Symposium on May 7. The conference was held at the Waldorf Astoria Monarch Beach Resort in Dana Point, CA.