Financial Services Hub

Analysis and commentary on financial services law, regulation, and business from Troutman Pepper Locke

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John Broughel, a 2026 summer associate with Troutman Pepper Locke who is not admitted to practice law in any jurisdiction, also contributed to this article.

Key Points

  • Transfers of performing loans into a continuation vehicle may trigger assignment, change-of-control, and consent provisions in fund-level credit agreements, requiring document review before any transfer closes.
  • Existing UCC

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John Norton, a 2026 summer associate with Troutman Pepper Locke who is not admitted to practice law in any jurisdiction, also contributed to this article.

Key Points

  • New York’s UCC amendments, effective June 3, 2026, add Article 12 and allow for an additional perfection method, “control,” for controllable electronic records (CERs) used as collateral.
  • A

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The Road to Housing Act takes aim at one of the most persistent pain points in community banking: the risk that everyday deposit relationships — particularly those involving custodial arrangements and reciprocal deposit networks — get swept into the regulatory definition of “brokered deposits.” Sections 901 and 902 of the legislation offer meaningful, targeted relief,…

Key Points

  • DOJ has reportedly directed all 93 U.S. Attorneys’ Offices to maintain a minimum of 25 open matters per prosecutor, a metrics-driven mandate that has drawn criticism as unworkable for complex white-collar and national security cases. 
  • The quota could incentivize earlier and more aggressive initiation of investigations, increasing the likelihood of grand jury subpoenas,

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On July 7, the U.S. Securities and Exchange Commission (SEC) announced the creation of a new Retail Fraud Working Group within its Division of Enforcement. The initiative represents a structural expansion of the SEC’s enforcement capabilities and has direct implications for broker-dealers, investment advisers, and other regulated entities that serve retail clients. This is consistent…

On May 6, the Financial Stability Board (FSB) released its first dedicated report on the private credit market’s vulnerabilities, and the findings land squarely on banks and fund managers. With private credit now at $1.5 trillion to $2 trillion globally, the FSB warns that circular funding structures, opaque borrower credit quality, and deepening interconnectedness between…

Key Points

  • On June 22, FinCEN and four co-regulators published a joint proposed rule under Section 4(a)(5)(A) of the GENIUS Act that would treat all PPSIs as BSA financial institutions and require them to maintain written CIP programs.
  • The proposed rule applies to every category of PPSI — including subsidiaries of insured depository institutions, OCC-chartered

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ATLANTA — Troutman Pepper Locke advised Georgia Banking Company, Inc. (GBC), parent company of Georgia Banking Company, in the completion of a $77.7 million private placement of primary and secondary shares, led by funds managed by affiliates of Fortress Investment Group. For more information, see the press release.…

On June 12, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an updated fact sheet on § 314(b) of the USA PATRIOT Act, replacing its December 2020 version. The update clarifies the permissibility of real-time information sharing, expands guidance on fraud-related sharing, and addresses several questions about who can participate and…