ATLANTA – Troutman Pepper Locke represented Repay Holdings Corporation (REPAY), a leading provider of integrated payment processing solutions, in a definitive agreement to acquire Kubra Data Transfer Ltd. (KUBRA) for approximately $372 million. The acquisition will be financed with a combination of cash on hand and debt financing. For more information, see the press release.
On March 19, the Federal Reserve, Federal Deposit Insurance Corporation (FDIC), and Office of the Comptroller of the Currency (OCC) (collectively, the agencies) jointly issued three proposed rules to “modernize” the regulatory capital framework for banking organizations of all sizes. The agencies aim to simplify how capital is calculated, better align requirements with underlying risk, and maintain the strength of the banking system, even as they project a modest decline in aggregate capital requirements compared to today’s levels. Comments on all three proposals are due by June 18, 2026.
The U.S. credit card industry is staring down a two-pronged policy challenge.
On one front, the Credit Card Competition Act (CCCA) is intended to foster increased competition in credit card merchant transaction routing so as to engender downward pressure on network interchange fees. On the other, a push to cap credit card Annual Percentage Rates
In Sztrom v. SEC, the U.S. District Court for the District of Columbia confirmed that the U.S. Supreme Court’s 2024 decision in SEC v. Jarkesy, which curtailed the Securities and Exchange Commission’s (SEC) ability to seek civil penalties in its administrative forum, does not eliminate the agency’s long-standing ability to pursue industry bars through administrative follow-on proceedings. The opinion underscores that, even after Jarkesy and other recent limits on agency power, the SEC may still use its in-house process to determine whether to bar previously enjoined defendants from the securities industry, with independent review limited to the courts of appeals.
On March 11, the Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) signed a memorandum of understanding (MOU) that both agencies describe as “historic.” The MOU is intended to reset the relationship between the agencies by reducing turf battles, avoiding duplicative regulation, and providing clearer, technology-neutral oversight — particularly in markets where securities and derivatives regimes overlap, including crypto. While it does not change either agency’s statutory authority, it creates a formal framework for coordination that will materially affect how policy, examinations, and enforcement play out in practice.
In a recent decision, the Delaware Court of Chancery held on summary judgment that a borrower’s grant of a security interest in substantially all of its assets, including its rights under a license agreement, constituted an “assignment” or “transfer” of such rights that triggered the license agreement counterparty’s contractual right of first negotiation (ROFN) and right of first refusal (ROFR). The decision has implications beyond the pharmaceutical licensing context in which it arose, and should prompt careful review of transfer restriction provisions in any agreement where a party may later seek to pledge its contractual rights as collateral.
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]
On March 5, 2026, the IRS issued proposed regulations (the Proposed Regulations) setting forth an alternative process for digital asset brokers to obtain consent from customers to receive Form 1099-DA statements electronically. This alternative process provided in the Proposed Regulations is meant to alleviate administrative tax compliance burdens for digital asset brokers. The IRS and Treasury also issued Notice 2026-4, requesting public comments on whether (i) less burdensome consent procedures should be implemented for other payee statements, including Form 1099-B, and (ii) the list of forms permitted on a Form 1099-B composite statement should include Form 1099-MISC for the purpose of reporting “staking rewards,” (i.e., additional units of cryptocurrency granted in exchange for holders locking up assets held in native cryptocurrency to help validate and secure the blockchain).
On February 11, the National Credit Union Administration (NCUA) released a proposed rule to implement the Guiding and Establishing National Innovation for U.S. Stablecoins Act (the GENIUS Act) for federally insured credit unions (FICUs). Under the proposal, credit unions cannot issue payment stablecoins directly. Instead, only NCUA‑licensed “permitted payment stablecoin issuers” (PPSIs) that are subsidiaries of FICUs would be allowed to issue payment stablecoins, and FICUs would be limited to investing only in PPSIs licensed by the NCUA.
On March 5, the Federal Deposit Insurance Corporation (FDIC), Federal Reserve Board, and Office of the Comptroller of the Currency (OCC) (collectively, the agencies) jointly issued FAQs clarifying how tokenized securities are treated under the federal regulatory capital rules.