When a commercial tenant files for bankruptcy, landlords encounter a complex set of legal and financial challenges. The bankruptcy process can affect everything from the payment of rent to the treatment of security deposits and letters of credit. Understanding these implications is essential for landlords seeking to protect their interests and maintain stability in their property portfolios.
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
James Stevens, co-leader of Troutman Pepper Locke’s Financial Services Industry Group, was quoted in the October 13, 2025 S&P Global Market Intelligence article, “US Banks’ Brokered Deposit Levels Would Drop Under Pending House Bills.”
On October 8, the Office of the Comptroller of the Currency (OCC), in collaboration with the Financial Crimes Enforcement Network (FinCEN), the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the National Credit Union Administration, released a set of frequently asked questions (FAQs) concerning Suspicious Activity Reports (SARs). These FAQs aim to clarify regulatory requirements related to SARs, assisting financial institutions in fulfilling their compliance obligations while optimizing resources for activities that provide the greatest value to law enforcement and other government users of Bank Secrecy Act (BSA) reporting.
On October 7, the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) unveiled two significant notices of proposed rulemaking (NPRs) designed to reshape the regulatory landscape for financial institutions. The first NPR aims to eliminate the use of reputation risk as a basis for regulatory actions, thereby reducing subjectivity in supervisory programs. This proposed rulemaking responds to concerns expressed in Executive Order 14331, Guaranteeing Fair Banking for All Americans, that the use of reputation risk can be a pretext for restricting law-abiding individuals’ and businesses’ access to financial services on the basis of political or religious beliefs or lawful business activities. The second NPR seeks to establish a clear definition of “unsafe or unsound practice” and revise the framework for issuing Matters Requiring Attention (MRAs) and other supervisory communications, with a focus on material financial risks. As of now, “unsafe or unsound practice” is not defined in the statute.
On October 6, the Office of the Comptroller of the Currency (OCC) announced a series of significant actions aimed at reducing the regulatory burden on community banks. These initiatives are part of the OCC’s ongoing efforts to tailor its regulatory and supervisory frameworks, thereby promoting economic growth and allowing community banks to better serve their
James Stevens, co-leader of Troutman Pepper Locke’s Financial Services Industry Group, was quoted in the October 7, 2025 Banking Dive article, “OCC Aims to Cut Community Bank Burden.”
The exam procedure changes, which take effect Jan. 1, give “more power to the on-site examiners to do the risk-based exams that they need, without
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
Register Here
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