On December 5, 2025, the Office of the Comptroller of the Currency (OCC) issued OCC Bulletin 2025-45, “Commercial Lending: Venture Loans to Companies in an Early, Expansion, or Late Stage of Corporate Development,” which rescinds OCC Bulletin 2023-34, “Commercial Lending: Venture Loans to Companies in an Early, Expansion, or Late Stage of Corporate Development.” The OCC’s message in issuing the new bulletin to replace the prior bulletin is straightforward: the agency does not want to discourage prudent venture lending. At the same time, it expects banks to recognize that venture loans carry materially higher default risk than conventional commercial loans and to manage that risk through disciplined underwriting, realistic risk ratings, and appropriate reserves.[1]

2025 was another consequential year in the consumer finance industry. On the federal level, President Donald Trump started his second term in January 2025 and since then has led an unprecedented rollback of federal agency oversight, impacting everything from the Consumer Financial Protection Bureau to the Federal Trade Commission. State legislatures, regulators, and attorneys general moved quickly to fill the resulting void.

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.

The digital asset landscape took a leap forward this summer when the U.S. Court of Appeals for the Ninth Circuit confirmed[1] that nonfungible tokens (NFTs) qualify for trademark protection under the Lanham Act.[2] This decision, centered on the Bored Ape Yacht Club’s collection of 10,000 distinctive digital ape NFTs, signals a new era for both intellectual property and secured lending.

On September 30, 2025, the Office of the Chief Counsel of the Securities and Exchange Commission’s (SEC) Division of Investment Management (the Division) issued a no-action response (the No-Action Letter) stating that it would not recommend enforcement against registered investment advisers (RIAs) or certain regulated funds (i.e., registered investment companies and business development companies) for maintaining crypto assets and related cash and cash equivalents with certain state-chartered financial institutions (state trust companies) so long as particular conditions are met.[1] In doing so, the No-Action Letter permits regulated funds and RIAs to treat state trust companies as “banks” for purposes of the custody requirements of Investment Company Act of 1940, as amended (the 1940 Act), the Investment Advisers Act of 1940, as amended (the Advisers Act) and the rules thereunder.

Register Here
Tuesday, September 30 • 12:00 – 1:30 p.m. ET

Troutman Pepper Locke Partner Jay Jumper will be speaking on a panel for a webinar hosted by CBIZ.

During this virtual event, panelists will provide a comprehensive overview of how strategic thinking, emerging best practices, and the latest trends can empower companies to successfully

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.

Last week, TZP Management Associates, LLC (TZP), a New York-based private equity investment adviser, agreed to pay more than $680,000 in monetary relief to settle charges brought by the Securities and Exchange Commission (SEC) for breaches of fiduciary duty related to the calculation of management fees for TZP’s private fund clients. This enforcement action highlights the importance of adhering to fund partnership agreements and providing adequate disclosure of fee calculation and management practices to mitigate potential conflicts of interest.