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 Zoe Sagalow and Lauren Seay, “Regulators Rarely Give Credit Unions Full-Weighting in Bank M&A Reviews.” The article examines how federal bank regulators treat credit unions in competitive analyses for bank mergers, including when and how those institutions are counted as “significant competitors” and how their deposits are weighted relative to banks and thrifts.

2025 was another consequential year in the consumer finance industry. On the federal level, President Donald Trump started his second term in January 2025 and since then has led an unprecedented rollback of federal agency oversight, impacting everything from the Consumer Financial Protection Bureau to the Federal Trade Commission. State legislatures, regulators, and attorneys general moved quickly to fill the resulting void.

Today, the Securities and Exchange Commission’s (SEC) Division of Enforcement announced significant updates to its Enforcement Manual, the first comprehensive revision since 2017. These changes, which will now be reviewed annually, are designed to promote greater fairness, transparency, and efficiency in SEC investigations and enforcement actions.

WASHINGTON, D.C. – Troutman Pepper Locke advised Piper Sandler & Co., a leading investment bank, as sole placement agent in completing FVCBankcorp, Inc.’s $25 million private placement of its 6.75% fixed rate senior unsecured notes due March 1, 2029, to certain qualified institutional buyers and accredited investors. For more information, see the press release.

FinCEN has issued an order granting exceptive relief from the longstanding requirement that covered financial institutions (CFIs) identify and verify the beneficial owners of legal entity customers every time a new account is opened. CFIs now need to collect and verify beneficial ownership information once per customer and then update it only when risk or new information warrants. While CFIs must still comply with all other Bank Secrecy Act (BSA) and anti-money laundering and counter-financing terrorism (AML/CFT) obligations, the new order represents an easing of the requirements established by FinCEN’s Customer Due Diligence regulation (the 2016 CDD rule) regarding the diligence CFIs must perform on legal entity customers as part of AML/CFT programs. Companies should consider whether it makes sense to maintain stricter past compliance practices or revise current policies to fit the new rules based on an individualized risk assessment.

At the Securities Enforcement Forum New York 2026, held on February 5, U.S. Attorney for the Southern District of New York (SDNY) Jay Clayton outlined enforcement priorities that should capture the attention of prediction market operators, crypto market participants, and public companies. As reported by Law360, Clayton made clear that the SDNY is actively considering how existing laws apply to prediction markets and that he fully expects fraud cases to be brought in that space. He also stressed that crypto markets are not exempt from traditional fraud scrutiny and described an enforcement approach that encourages companies to self-report misconduct and cooperate in exchange for potential nonprosecution agreements.

On January 29, the U.S. Senate Committee on Agriculture, Nutrition, and Forestry (AG Committee), led by Chairman John Boozman (R‑AR), advanced S. 3755, the Digital Commodity Intermediaries Act (DCIA), on a party-line vote. The DCIA builds on the bipartisan, House-passed CLARITY Act to create a federal registration and compliance regime for key digital asset intermediaries. The DCIA also would provide a clear legal definition of “digital commodities” and establish a spot market digital commodity intermediary regulatory regime with the Commodity Futures Trading Commission (CFTC). In the press release, Chairman Boozman framed the vote as “a critical step toward creating clear rules for digital asset markets” that protect consumers while allowing innovation to thrive.

In 2025, the U.S. digital asset landscape evolved more dramatically than in any year since the industry’s inception. A pro‑innovation White House, an active Congress, and key regulators — including the U.S. Securities and Exchange Commission (SEC), the Commodity Futures Trading Commission (CFTC), the Office of the Comptroller of the Currency (OCC), the Department of…