James Stevens, co-leader of Troutman Pepper Locke’s Financial Services Industry Group, was quoted in the October 7, 2025 Banking Dive article, “OCC Aims to Cut Community Bank Burden.”
The exam procedure changes, which take effect Jan. 1, give “more power to the on-site examiners to do the risk-based exams that they need, without
On September 30, 2025, the new Texas Stock Exchange (TXSE) announced that the SEC approved its Form 1 registration statement, officially approving the exchange. Accordingly, the TXSE is now officially a recognized national securities exchange, similar to the Nasdaq Stock Market and the New York Stock Exchange, both of which the TXSE has expressly targeted as its main competitors in past public statements. In the TXSE’s own words, this makes it the “first fully integrated national securities exchange to receive SEC approval in decades” offering, within a single platform, a comprehensive suite of services, including listing standards, trading, clearing, settlement, and market data.
On September 26, Securities and Exchange Commission (SEC) Chair Paul S. Atkins announced a return to the SEC’s prior practice of allowing individuals and entities facing enforcement actions to request that the SEC simultaneously consider both their settlement offers and any related waiver requests. Waivers may be necessary to avoid automatic disqualifications and collateral consequences that can result from enforcement actions, such as the loss of well-known seasoned issuer status, safe harbor protections, private offering exemptions, or the ability to serve in certain regulated capacities.
On September 17, the New York State Department of Financial Services (DFS) issued new guidance on the use of blockchain analytics tools. This new guidance builds upon the blockchain guidance issued by DFS in 2022, and applies to all New York banking organizations and branches and agencies of foreign banking organizations that are licensed by the DFS (covered institutions).
The Report authored by the Presidential Working Group on Digital Assets Markets (PWG), titled “Strengthening American Leadership in Digital Financial Technology,” along with the accompanying fact sheet, outlines several key objectives aimed at positioning the U.S. as a leader in digital asset markets. Among its objectives are reinforcing the role of the U.S. dollar, modernizing Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT) rules for the digital assets ecosystem, and ensuring fairness and predictability by establishing clear regulatory oversight.
On September 8, the Office of the Comptroller of the Currency (OCC) took significant action to “depoliticize” the federal banking system by issuing two bulletins to banks that further the goals of Executive Order 14331 “Guaranteeing Free Banking for All Americans” (discussed here). The OCC’s press release announcing the bulletins explains that they are aimed at eliminating politicized or unlawful debanking practices and ensuring that banks provide access to financial services based on objective, risk-based analyses rather than political or religious beliefs. Bulletin 2025-22 clarifies how politicized or unlawful debanking will be assessed in licensing applications and Community Reinvestment Act (CRA) performance evaluations. Bulletin 2025-23 reminds banks of their legal obligations under the Right to Financial Privacy Act (RFPA) to protect customer financial records and ensure proper use of Suspicious Activity Reports (SARs).
In a significant move aimed at enhancing regulatory clarity and fostering global market access, particularly for offshore cryptocurrency firms, the U.S. Commodity Futures Trading Commission (CFTC) issued a new advisory on the Foreign Board of Trade (FBOT) registration framework. This development, announced on August 28, 2025, by Acting Chairman Caroline D. Pham, marks a pivotal step in aligning U.S. trading regulations with the evolving landscape of global derivatives markets.
Troutman Pepper Locke is pleased to announce that four of its financial services attorneys were recognized under the special designation of “Lawyer of the Year” in the 2026 edition of The Best Lawyers in America®, an honor earned by just one lawyer in each practice area and metropolitan area.
James Stevens, co-leader of Troutman Pepper Locke’s Financial Services Industry Group, and Greg Parisi will be presenting at Bank Director’s upcoming Bank Board Forum taking place September 8-10, 2025 at the JW Marriott Marco Island Beach Resort.
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