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Matthew Russell Morris

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Matt is an associate in the firm’s Corporate practice. He brings a wealth of experience from his diverse background in law, business, and finance. Matt earned his J.D., cum laude, from William & Mary Law School.

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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.

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.

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.

Troutman Pepper Locke advised Performance Trust Capital Partners, LLC in the successful completion of Chesapeake Financial Shares, Inc.’s private placement of $25 million in fixed-to-floating rate subordinated notes. The offering, which was significantly oversubscribed due to robust investor demand, will provide Chesapeake Financial Shares, Inc. with the capital needed to pursue growth opportunities and strengthen its balance sheet. For more information, read the press release.

Today, the Federal Deposit Insurance Corporation (FDIC) announced an extension of the comment period for its notice of proposed rulemaking (NPR) aimed at revising the 2020 Brokered Deposit Rule. To ensure that all interested parties have sufficient time to review the proposed changes and prepare their comments, the FDIC has extended the comment period from October 22, 2024, to November 21, 2024.

This article was quoted on Finance Magnates on March 10, 2025.

Guest Contributors: Jonah Crane and Adam Shapiro of Klaros Group

This is the second of three articles focused on a key question: as bank-fintech partnerships continue to play a vital role in driving financial services, how does the industry make this system safer and better?

In this second article,[i] we focus on encouraging the industry and regulators to adopt the right lessons from Synapse Financial Technologies’ (Synapse) bankruptcy by drawing from the root causes of its failure. We offer some best practices and discuss the potential role of the Federal Deposit Insurance Corporation’s (FDIC) recently proposed recordkeeping rule (Records NPR) — including areas of potential improvement — and conclude by noting how enhanced account ledgering by banks helps address one root cause of the Synapse failure: faulty account ledgering performed only by a third party.

This is the first of three articles focused on a key question: as bank-fintech partnerships continue to play a vital role in driving financial services, how does the industry make this system safer and better?

Fintechs and their partner banks are on edge. Regulators are concerned. But as counselors to a wide range of banks and nonbanks, we are confident that the bank-fintech partnership model is not broken. We have seen these partnerships work well — not just for clients, but for consumers and other end-users — with rigorous, risk-based controls that satisfy both the regulators and the public.

On July 30, 2024, the FDIC proposed substantive changes to the 2020 Brokered Deposit Rule (2020 Rule) that, if finalized, could meaningfully impact a wide group of bank and nonbank stakeholders who rely on the current rule’s definition of “deposit broker,” related exceptions, and Q&As. Many of the proposed changes effectively reverse the 2020 Rule.