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November 12 – 14, 2025

Members of Troutman Pepper Locke’s Financial Services Industry Group are set to speak at the upcoming Third Party Payment Processor’s Annual Conference, “Solving the Payment Puzzle.” This event offers attendees valuable insights into the latest developments in payments and compliance.

Thursday, November 6 • 8:30 a.m. – 3:30 p.m. ET

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Troutman Pepper Locke is proud to sponsor the Community Bankers Association of Georgia’ 2025 Tech Talk – North conference, being held on November 6 in Atlanta, Georgia. James Stevens, co-leader of Troutman Pepper Locke’s Financial Services Industry Group, will be presenting on Regulatory

When a tenant in a shopping center files for bankruptcy, Section 365(b)(3) of the Bankruptcy Code provides special protections for landlords that go beyond those available for other commercial leases. These protections require any potential assignee of a shopping center lease to comply with exclusivity and use provisions, maintain the existing tenant mix, and meet financial standards similar to the original tenant. As a result, landlords can block assignments to undesirable tenants, but buyers must carefully review lease terms and co-tenant agreements before bidding on a debtor’s lease.

Last May, we provided a client alert about a recent federal district court case (Spence v. American Airlines, No. 4:23-cv-00552-O, 2025 WL 225127, at *2 (N.D. Tex. Jan. 10, 2025)), in which a plan sponsor and certain plan fiduciaries were found to have breached their ERISA fiduciary duty of loyalty based primarily on conduct related to proxy voting of securities held in certain of the 401(k) plans’ investment funds. At that time, the court left open the question of whether the breach resulted in any damages to the participants.

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 + Enforcement Practice

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

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.