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Troutman Pepper Locke’s Securities Investigations + Enforcement Practice

Our Securities Investigations + Enforcement practice has expanded significantly due to our recent merger, enhancing our capabilities nationwide, including in our San Francisco, Dallas, and New York offices. We counsel and defend clients throughout all stages of securities enforcement proceedings, representing a diverse range of clients, including major financial institutions, senior corporate executives, boards of directors, and various entities in the financial services industry. Our team handles investigations by regulatory bodies such as the SEC, FINRA, and the Department of Justice. Leveraging decades of experience and including former key government officials, we develop informed and effective strategies tailored to each client’s unique needs. To read more about our capabilities, please click here.

On April 8, the Office of the Comptroller of the Currency (OCC) officially notified Congress of a significant information security incident involving its email system. This notification, mandated by the Federal Information Security Modernization Act, follows the discovery of unauthorized access to OCC emails and attachments that included highly sensitive information related to the financial condition of federally regulated financial institutions.

Guest contributors: Ashley Harris, Thomas Scott, and Isabelle Corbett Sterling, BakerHostetler

This is the final article in our three-part series 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 final part of our series, we propose a DLT-based account ledgering model designed to prevent failures like Synapse while offering broader benefits. Previously, we examined Synapse’s collapse, the misplaced trust in its ledgers, and potential regulatory responses,[1] including concerns about the Federal Deposit Insurance Corporation’s (FDIC) proposed recordkeeping rule (Records NPR).[2]

On March 28, the Federal Reserve Board, the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (together, the federal banking agencies) announced their intent to rescind the 2023 Community Reinvestment Act (CRA) final rule and reinstate the previous CRA framework. This decision comes in light of pending litigation in the Fifth Circuit by various banking trade associations contesting the rules by alleging regulatory overreach. The agencies stated they will continue to work together to promote a consistent regulatory approach to implementation of the CRA.

Last Friday, the Federal Deposit Insurance Corporation (FDIC) announced the rescission of Financial Institution Letter (FIL-16-2022) and issued new guidance clarifying the process for FDIC-supervised institutions to engage in crypto-related activities. The new Financial Institution Letter (FIL-7-2025) represents a 180 degree turn from the prior Chairman’s position, which required prior notification and relevant information by banks seeking to engage in crypto-related activities.

On March 20, the Office of the Comptroller of the Currency (OCC) announced that it will no longer examine its regulated institutions for reputation risk. According to the OCC’s “Categories of Risk,” reputation risk is the risk to earnings or capital arising from negative public opinion, which can affect an institution’s ability to establish new relationships or services or to continue servicing existing relationships. The decision to stop examining banks for reputation risk comes in the wake of the introduction of the Financial Integrity and Regulation Management (FIRM) Act, which aimed to eliminate reputational risk as a component of the supervision of depository institutions.

On March 17, the Office of the Comptroller of the Currency (OCC) announced that it has granted conditional approval for SmartBiz Loans to transform the business model of CenTrust Bank, N.A., located in Northbrook, Illinois. This approval follows SmartBiz Loans’ acquisition of CenTrust Bank, N.A., which has since been renamed SmartBiz Bank, N.A. The approval allows SmartBiz Bank, N.A. to expand its small business lending activities on a nationwide scale.