Alex Barrage, a partner in Troutman Pepper Locke’s Financial Services Industry Group, was quoted in the January 27, 2025 Washington Post article, “Banking Regulator Rescinds More Than 200 Job Offers for Examiners It Needs.”
Analysis and commentary on financial services law, regulation, and business
Alex Barrage, a partner in Troutman Pepper Locke’s Financial Services Industry Group, was quoted in the January 27, 2025 Washington Post article, “Banking Regulator Rescinds More Than 200 Job Offers for Examiners It Needs.”
Troutman Pepper Locke attorneys Alexandra Steinberg Barrage, Matthew Bornfreund, and James Stevens, along with Michele Alt of Klaros Group and other leading banking and financial services professionals, released an open letter to the incoming administration outlining concrete ways the FDIC, OCC, and Federal Reserve Board (Agencies) could encourage new and innovative bank formation.
This week, President Trump designated National Credit Union Administration (NCUA) Vice Chairman Kyle Hauptman as the thirteenth Chairman of the NCUA Board. Hauptman succeeds Todd Harper as NCUA Chairman. In the press release announcing his appointment, Chairman Hauptman said, “I am deeply honored that President Trump has asked me to serve as Chairman of NCUA. I look forward to leading the agency’s dedicated professionals and working with my Board colleagues to create a regulatory structure that promotes growth, opportunity, and innovation within the credit union system.”
When an employer files for bankruptcy, employees often worry about the fate of their severance payments. Under Section 503(b)(1)(A) of the Bankruptcy Code, wages, salaries, and commissions for services rendered after the commencement of the bankruptcy case are treated as administrative expense claims. Additionally, Section 507(a)(4) grants priority status to wages, salaries, or commissions, including severance, earned within 180 days of the bankruptcy filing, up to a statutory cap. These provisions aim to protect employees’ compensation but apply to different time periods and have varying priority levels, which can impact severance payments differently.
On January 20, Travis Hill became the Acting Chairman of the Federal Deposit Insurance Corporation (FDIC). Following his remarks on FDIC policy issues on January 10 at the American Bankers Association, in his first statement as Acting Chairman, Hill highlighted various priorities and mentioned new initiatives, emphasizing a commitment to regulatory reform, innovation, and a focus on core financial risks.
Days before President Biden leaves the White House, the U.S. government has delivered a major blow against Russia. On January 10, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced its most comprehensive sanctions to-date against Russia’s energy sector. OFAC’s sanctions were complemented by another sweeping sanctions action by the U.S. Department of State (State Department) on the same day.
James Stevens, co-leader of Troutman Pepper Locke’s Financial Services Industry Group, was quoted in the January 15, 2025 Banking Dive article, “BaaS Outlook Brighter After Period of Growing Pains.”
On January 10, the Consumer Financial Protection Bureau (Bureau) issued a notice of proposed interpretive rule (Proposed Rule). The deadline for comments is March 31, 2025. The Proposed Rule would apply the Electronic Fund Transfer Act (EFTA)—which protects consumers against errors and fraud—to new types of digital payment mechanisms, including stablecoins and other digital currencies.
On January 8, the United States District Court for the Southern District of New York dismissed the claims brought by Banco San Juan Internacional, Inc. (BSJI) against the Federal Reserve Bank of New York (FRBNY) and the Board of Governors of the Federal Reserve System (Board). BSJI alleged that the termination of its master account by the FRBNY violated various federal laws. The ruling in the BSJI case underscores the discretionary authority of Federal Reserve Banks in granting or denying master accounts.
When a company files for Chapter 11 bankruptcy, it must navigate numerous challenges and adapt to operating under the Bankruptcy Code. To facilitate this transition, the company typically files a series of motions known as “First-Day Motions” shortly after the bankruptcy petition is filed. These motions aim to prevent a complete shutdown of operations and reduce administrative burdens. They are addressed at a “First-Day Hearing,” which usually occurs within one or two days of the case commencement.
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