The New York Limited Liability Company Transparency Act (NYLTA) took effect on January 1, 2026. We previously wrote about the NYLTA when it was first introduced and when it was subsequently repealed and reintroduced. A combination of federal regulatory developments and Governor Kathy Hochul’s December 2025 veto of a proposed state amendment have substantially
On August 11, 2026, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule (Final Rule) confirming the implementation of the relief and clarifications regarding the Corporate Transparency Act (CTA) contemplated by the March 21, 2025 interim rule (Interim Rule) covered in our March 25, 2025, and April 22
On August 5, the SOLO Network announced a FinCEN-observed bank reliance pilot developed in coordination with the U.S. Department of the Treasury, the Financial Crimes Enforcement Network (FinCEN), the Office of the Comptroller of the Currency (OCC), and the Federal Deposit Insurance Corporation (FDIC). The pilot represents the first coordinated engagement across all four agencies
The Senate adjourned on August 8, 2026 without holding a final vote on the Clarity Act. However, Senate Majority Leader John Thune filed cloture on the motion to proceed to the Clarity Act shortly before the Senate left for recess, setting up a procedural vote for September 15, 2026, the day after the Senate returns
Key Points
On July 27, the OCC requested public comment on the forms entities would file to apply to issue payment stablecoins under the GENIUS Act, and the forms foreign issuers would file to register. They show how the licensing and registration process in the OCC’s March 2 proposed rule would work in practice: what an applicant
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 the Division of Enforcement at the SEC, former
On June 16, the Office of the Comptroller of the Currency (OCC) issued a cease and desist order against United Texas Bank, N.A. citing deficiencies in its Bank Secrecy Act/anti-money laundering (BSA/AML) compliance program that resulted in violations of law or regulation. The action is notable not only for its substance, but for its context.
Earlier this year, on May 18, the National Credit Union Administration (NCUA) Board published its second notice of proposed rulemaking implementing the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act). The proposal sets operating standards for permitted payment stablecoin issuers (PPSIs) that are subsidiaries of federally insured credit unions and updates the
On June 5, the California Department of Financial Protection and Innovation (DFPI) published a Notice of Second Modification to Text of Proposed Regulation under the Digital Financial Assets Law (DFAL). The modifications respond to the Office of Administrative Law’s (OAL) disapproval of the rulemaking: OAL issued a Notice of Disapproval on May 12 and, on