On November 10, 2025, the IRS issued Rev. Proc. 2025-31 (the Rev Proc.), which provides a safe harbor for investment trusts and grantor trusts to stake certain digital assets without jeopardizing their status as trusts for U.S. federal income tax purposes. The Rev. Proc. comes in response to the White House’s request made in July 2025 for published guidance on this topic.[1]

Thursday, November 6 • 8:30 a.m. – 3:30 p.m. ET

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Troutman Pepper Locke is proud to sponsor the Community Bankers Association of Georgia’ 2025 Tech Talk – North conference, being held on November 6 in Atlanta, Georgia. James Stevens, co-leader of Troutman Pepper Locke’s Financial Services Industry Group, will be presenting on Regulatory

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

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.

Wednesday, October 8 • 8:00 a.m. – 4:15 p.m. ET
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James Stevens, co-leader of Troutman Pepper Locke’s Financial Services Industry Group, will be presenting at the Banking Beyond Boundaries: Fintech and Financial Innovation Conference, hosted by the Bank of North Dakota, on Wednesday, October 8. James will be speaking on a panel discussing

On September 19, the U.S. Department of the Treasury issued an Advance Notice of Proposed Rulemaking (ANPRM) seeking public input on the implementation of the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act. This ANPRM builds upon the Request for Comment on Innovative Methods to Detect Illicit Activity Involving Digital Assets issued by Treasury on August 18, which remains open for comment until October 17, 2025.

On September 19, the U.S. Department of the Treasury issued an Advance Notice of Proposed Rulemaking (ANPRM) seeking public input on the implementation of the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act. This ANPRM builds upon the Request for Comment on Innovative Methods to Detect Illicit Activity Involving Digital Assets issued by Treasury on August 18, which remains open for comment until October 17, 2025.

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.