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Seth A. Winter

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Seth represents publicly traded companies and financial institutions, including banks and bank holding companies, nonbank lenders, and other fintech and financial services companies, on regulatory, compliance, strategic, corporate law, securities law, and disclosure matters.

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On August 27, the Office of the Comptroller of the Currency (OCC) announced a series of significant actions designed to improve transparency, consistency, and clarity in bank supervision and enforcement. The actions — which include a joint final rule with the Federal Deposit Insurance Corporation (FDIC), two revised policies and procedures manuals (PPMs), and a proposed rulemaking — reflect the agencies’ stated commitment to refocusing supervisory attention on material financial risks over process, documentation, and other nonfinancial concerns. Notably, the Federal Reserve did not join in these actions, and as of the date of this post, has not issued any comparable guidance or commentary.

The Office of the Comptroller of the Currency (OCC) is reportedly moving to give community banks more time between examinations under the Community Reinvestment Act (CRA), the federal anti-redlining statute that shapes how banks serve low- and moderate-income communities. As reported by Bloomberg Law, based on a May 15 supervisory memorandum obtained by the publication, the OCC has revised its exam cycle expectations for community and small regional banks that demonstrate strong CRA performance.

The federal banking agencies have finalized a significant recalibration of the Community Bank Leverage Ratio (CBLR) framework. In a joint final rule, the Office of the Comptroller of the Currency (OCC), the Federal Reserve Board, and the Federal Deposit Insurance Corporation (FDIC) (collectively, the agencies) have lowered the CBLR requirement from 9% to 8% and lengthened the grace period for certain temporary breaches of the CBLR criteria. The rule becomes effective July 1, 2026, and is intended to deliver more meaningful regulatory relief while preserving supervisory comfort with capital adequacy and safety and soundness.

On March 19, the Federal Reserve, Federal Deposit Insurance Corporation (FDIC), and Office of the Comptroller of the Currency (OCC) (collectively, the agencies) jointly issued three proposed rules to “modernize” the regulatory capital framework for banking organizations of all sizes. The agencies aim to simplify how capital is calculated, better align requirements with underlying risk, and maintain the strength of the banking system, even as they project a modest decline in aggregate capital requirements compared to today’s levels. Comments on all three proposals are due by June 18, 2026.

WASHINGTON, D.C. – Troutman Pepper Locke advised Piper Sandler & Co., a leading investment bank, as sole placement agent in completing FVCBankcorp, Inc.’s $25 million private placement of its 6.75% fixed rate senior unsecured notes due March 1, 2029, to certain qualified institutional buyers and accredited investors. For more information, see the press release.

In 2025, the U.S. digital asset landscape evolved more dramatically than in any year since the industry’s inception. A pro‑innovation White House, an active Congress, and key regulators — including the U.S. Securities and Exchange Commission (SEC), the Commodity Futures Trading Commission (CFTC), the Office of the Comptroller of the Currency (OCC), the Department of…

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.

This article was republished in Law360 on March 13, 2026.

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.”

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.