ATLANTA – Troutman Pepper Locke advised Georgia Banking Company, Inc. (GBC), parent company of Georgia Banking Company, in the completion of a $55.0 million private placement of 6.75% Fixed-to-Floating Rate Subordinated Notes due September 1, 2036. The Notes have been structured to qualify as Tier 2 capital under bank regulatory capital guidelines. GBC intends to use the net proceeds to replace existing debt and for general corporate purposes. For more information, click here.
James Stevens, partner and co-leader of Troutman Pepper Locke’s Financial Services Industry Group, was quoted in a recent article by Emily McCormick, “When the Holding Company Isn’t a Source of Strength.” The article examines the tensions that can arise between bank holding companies and their subsidiary banks, and what directors should do when those interests diverge.
On August 31, the U.S. Securities and Exchange Commission (SEC) and the U.S. Food and Drug Administration (FDA) executed a Memorandum of Understanding (MOU) establishing a formal framework for sharing nonpublic information between the two agencies. The MOU takes effect immediately upon signature and reflects a significant step toward coordinated regulatory and enforcement activity at the intersection of public health and financial markets.
On August 27, the Office of the Comptroller of the Currency (OCC) announced a series of significant actions designed to improve transparency, consistency, and clarity in bank supervision and enforcement. The actions — which include a joint final rule with the Federal Deposit Insurance Corporation (FDIC), two revised policies and procedures manuals (PPMs), and a proposed rulemaking — reflect the agencies’ stated commitment to refocusing supervisory attention on material financial risks over process, documentation, and other nonfinancial concerns. Notably, the Federal Reserve did not join in these actions, and as of the date of this post, has not issued any comparable guidance or commentary.
On August 18, the U.S. Department of the Treasury (Treasury) published a notice of proposed rulemaking in the Federal Register to implement § 3 of the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act or Act) — the first comprehensive federal regulatory framework for payment stablecoins in the U.S., enacted on July 18, 2025. A payment stablecoin is a digital asset that is, or is designed to be, used as a means of payment or settlement, and whose issuer is obligated to convert, redeem, or repurchase it for a fixed amount of monetary value while maintaining a stable value relative to that amount. The GENIUS Act expressly excludes national currencies, bank deposits, and securities from the definition of payment stablecoins.
FinCEN’s decision to exempt all domestic reporting companies from beneficial ownership information (BOI) reporting has significant implications for financial institutions’ anti-money laundering (AML) compliance programs. The change removes a filing obligation for many U.S. businesses, but it does not change the need to determine who owns, controls, and benefits from a legal entity. Covered financial institutions must continue to identify and verify the beneficial owners of legal-entity customers under their customer due diligence (CDD) obligations, although FinCEN has provided limited relief from repeating that process when an existing customer opens a new account. This alert explains what changed and the steps institutions should take to adjust their controls.
James Stevens, partner and co-leader of Troutman Pepper Locke’s Financial Services Industry Group, was quoted in a recent S&P Global Market Intelligence article by Claire Lawson, “Bank7 Eyes Expansion, Low-Cost Deposits in Unconventional Century Financial Play.” The article examines Bank7 Corp.’s unusual attempt to acquire a 71% ownership stake in Century Financial Services Corp. through a stalking horse bid in the U.S. District Court of Arizona. Industry observers have described this structure as highly uncommon in the bank M&A space.
The New York Limited Liability Company Transparency Act (NYLTA) took effect on January 1, 2026. We previously wrote about the NYLTA when it was first introduced and when it was subsequently repealed and reintroduced. A combination of federal regulatory developments and Governor Kathy Hochul’s December 2025 veto of a proposed state amendment have substantially narrowed the statute’s scope. Only nonexempt LLCs formed under the laws of a foreign country that are authorized to do business in New York are now subject to its beneficial ownership information (BOI) reporting requirements. All LLCs formed under the laws of any U.S. state or territory are exempt from reporting under the NYLTA as it currently stands.
On August 11, 2026, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule (Final Rule) confirming the implementation of the relief and clarifications regarding the Corporate Transparency Act (CTA) contemplated by the March 21, 2025 interim rule (Interim Rule) covered in our March 25, 2025, and April 22, 2025, client alerts. The Final Rule took effect on August 14, 2026, upon its publication in the Federal Register. By removing the requirement for U.S. companies and U.S. persons to report beneficial ownership information (BOI) under the CTA, the Final Rule represents a significant rollback of much of a reporting regime that had imposed compliance obligations on millions of small and mid-sized businesses across the U.S. FinCEN has also announced it will delete previously reported information submitted by U.S. persons from its BOI database.