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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 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.

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…