Fintech

Key Points

  • The SEC proposed Regulation Crypto Assets (Reg CA) on August 18, 2026, creating the first purpose-built offering regime for crypto assets under federal securities laws.
  • Reg CA would establish two non-exclusive exemptions from Securities Act registration: a startup exemption permitting offerings up to $5 million over four years and a fundraising exemption permitting

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Key Points

  • On June 22, FinCEN and four co-regulators published a joint proposed rule under Section 4(a)(5)(A) of the GENIUS Act that would treat all PPSIs as BSA financial institutions and require them to maintain written CIP programs.
  • The proposed rule applies to every category of PPSI — including subsidiaries of insured depository institutions, OCC-chartered

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In this episode of Regulatory Oversight, co-host Stephen Piepgrass sits down with Jay Dubow and Ghillaine Reid, co-leaders of the firm’s Securities Investigation + Enforcement practice, to explore how the SEC’s enforcement agenda is evolving under Chairman Paul Atkins and what that means for public companies, financial institutions, and their executives.…

Troutman Pepper Locke’s Securities Investigations + Enforcement Practice

Troutman Pepper Locke’s Securities Investigations and Enforcement team counsels and defends clients through all stages of securities enforcement proceedings. Our attorneys have served in key government agencies and regulatory bodies, and bring their insight to bear in each representation. The team includes a former branch chief of…

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…