In this special crossover edition of the Payments Pros and Crypto Exchange podcast, Carlin McCrory is joined by colleagues Alex Barrage and Ethan Ostroff to discuss recent legislative updates surrounding payment stablecoins....more
4/24/2025
/ Anti-Money Laundering ,
Cryptocurrency ,
Financial Regulatory Reform ,
Financial Services Industry ,
FinTech ,
New Legislation ,
Payment Systems ,
Regulatory Requirements ,
Securities and Exchange Commission (SEC) ,
Securities Regulation ,
Stablecoins
This is the final article in our three-part series focused on a key question: as bank-fintech partnerships continue to play a vital role in driving financial services, how does the industry make this system safer and better?...more
4/8/2025
/ Banks ,
Bitcoin ,
Blockchain ,
Distributed Ledger Technology (DLT) ,
Ethereum ,
FDIC ,
Financial Institutions ,
Financial Services Industry ,
FinTech ,
Investment ,
Regulatory Requirements ,
Risk Management ,
Securities Tokens ,
Smart Contracts
Last Friday, the Federal Deposit Insurance Corporation (FDIC) announced the rescission of Financial Institution Letter (FIL-16-2022) and issued new guidance clarifying the process for FDIC-supervised institutions to engage in...more
4/1/2025
/ Banks ,
Consumer Financial Products ,
Cryptocurrency ,
Digital Assets ,
FDIC ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
FinTech ,
New Guidance ,
OCC ,
Regulatory Oversight
Alex Barrage, a partner in Troutman Pepper Locke’s Financial Services Industry Group, was quoted in the March 13, 2025 American Banker article, “Banks Are Pushing Back Against Stablecoin Legislation.”...more
On March 7, the Office of the Comptroller of the Currency (OCC) issued a significant update regarding the involvement of national banks and federal savings associations in cryptocurrency activities. Interpretive Letter 1183...more
3/13/2025
/ Banks ,
Blockchain ,
Cryptoassets ,
Cryptocurrency ,
Digital Assets ,
Financial Institutions ,
Financial Services Industry ,
FinTech ,
Interpretive Letters ,
OCC ,
Regulatory Requirements ,
Risk Management
On January 8, Senate Bill No. 1252 (SB 1252) was introduced to the Virginia General Assembly, aiming to amend and reenact sections of the Code of Virginia related to the application of usury rates. Just two weeks ago, the...more
2/28/2025
/ Banks ,
Consumer Financial Products ,
Financial Institutions ,
Financial Services Industry ,
FinTech ,
Interest Rates ,
Loans ,
Proposed Legislation ,
Regulatory Agenda ,
Regulatory Reform ,
Regulatory Requirements
On January 16, U.S. Representative Andy Barr (R-KY) introduced H.R. 478, the “Promoting New Bank Formation Act,” which was referred to the Committee on Financial Services. This bill aims to support the establishment and...more
2/27/2025
/ Agribusiness ,
Agricultural Land ,
Capital Requirements ,
Community Banks ,
Equal Access to Credit ,
FDIC ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Loans ,
Regulatory Agenda ,
Regulatory Requirements ,
Rural Areas ,
Small Business
In this special crossover episode of the Payments Pros and Crypto Exchange podcasts, our hosts are joined by colleague Alexandra Steinberg Barrage to discuss California's Department of Financial Protection and Innovation’s...more
In this special crossover episode of the Payments Pros and Crypto Exchange podcasts, our hosts are joined by colleague Alexandra Steinberg Barrage to discuss California's Department of Financial Protection and Innovation’s...more
In the last two weeks, several amicus briefs were filed in the Tenth Circuit in the ongoing litigation concerning Colorado’s opt-out from the Depository Institutions Deregulation and Monetary Control Act (DIDMCA). Troutman...more
12/5/2024
/ Amicus Briefs ,
Banks ,
Colorado ,
Consumer Financial Products ,
DIDMCA ,
Financial Regulatory Reform ,
Financial Services Industry ,
Interest Rates ,
Loans ,
Opt-Outs ,
Preliminary Injunctions
In a previous post, we discussed the Federal Deposit Insurance Corporation’s (FDIC) notice of proposed rulemaking aimed at enhancing recordkeeping for bank deposits received from fintech and other third-party, non-bank...more
11/20/2024
/ Bank Deposits ,
Comment Period ,
FDIC ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
NPRM ,
Proposed Rules ,
Public Comment ,
Recordkeeping Requirements ,
Third-Party
Yesterday, the Federal Deposit Insurance Corporation (FDIC) announced an extension of the comment period for its notice of proposed rulemaking (NPR) aimed at revising the 2020 Brokered Deposit Rule. To ensure that all...more
We previously posted on the Federal Deposit Insurance Corporation’s (FDIC) notice of proposed rulemaking aimed at enhancing recordkeeping for bank deposits received from fintech and other third-party, non-bank companies....more
10/7/2024
/ Bank Deposits ,
Comment Period ,
FDIC ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Nonbank Firms ,
Notice of Proposed Rulemaking (NOPR) ,
Proposed Rules ,
Recordkeeping Requirements ,
Regulatory Agenda ,
Third-Party
This is the second of three articles focused on a key question: as bank-fintech partnerships continue to play a vital role in driving financial services, how does the industry make this system safer and better?...more
10/4/2024
/ Bankruptcy Code ,
Banks ,
Commercial Bankruptcy ,
Consumer Financial Products ,
FDIC ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
FinTech ,
Recordkeeping Requirements ,
Risk Management
On September 17, the Federal Deposit Insurance Corporation (FDIC) announced a notice of proposed rulemaking (Proposal) aimed at enhancing recordkeeping for bank deposits received from fintech and other third-party, non-bank...more
9/19/2024
/ Banks ,
FDIC ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
FinTech ,
New Rules ,
Notice of Proposed Rulemaking (NOPR) ,
Recordkeeping Requirements ,
Regulatory Agenda ,
Third-Party
These office hours provide a one-to-one engagement opportunity for organizations to share their stories, offer viewpoints, or gain insights into the regulatory and supervisory landscape....more
This is the first of three articles focused on a key question: as bank-fintech partnerships continue to play a vital role in driving financial services, how does the industry make this system safer and better?...more
Some advisers suggested the bank regulatory agencies could join forces without this proposed rule, though they have not always coordinated on various works in the past. Although the agencies could collaborate informally,...more
“In the worst case, these [newly designated brokered deposits] will have to get offloaded in a way that potentially puts those banks at even greater liquidity risk, especially to the extent that they have a higher...more
“I would say a lot of these fintechs deposits are actually the opposite of hot money,” said Matthew Bornfreund, a partner at Troutman Pepper. “I think a problem with this proposed rulemaking is, the FDIC asserts that these...more
On July 30, 2024, the FDIC proposed substantive changes to the 2020 Brokered Deposit Rule (2020 Rule) that, if finalized, could meaningfully impact a wide group of bank and nonbank stakeholders who rely on the current rule’s...more
Last week, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (collectively, the agencies) issued a joint statement highlighting...more
7/29/2024
/ AML/CFT ,
Anti-Money Laundering ,
Banks ,
Consumer Financial Products ,
Customer Due Diligence (CDD) ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
Financial Services Industry ,
FinTech ,
Joint Statements ,
OCC ,
Risk Management ,
Suspicious Activity Reports (SARs) ,
Third-Party Relationships
Alexandra Barrage, a partner in Troutman Pepper’s Corporate Practice Group, was quoted in the July 10, 2024 Law360 article, “Pledging ‘Accountability,’ Biden’s FDIC Pick Faces Senate Test.”...more
As discussed here, on June 28, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) proposed significant amendments to the anti-money laundering and countering the financing of terrorism...more
7/29/2024
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Regulators ,
Consumer Financial Products ,
Credit Unions ,
Financial Crimes ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
FinCEN ,
Money Laundering ,
Notice of Proposed Rulemaking (NOPR) ,
Proposed Rules ,
Risk Assessment ,
Suspicious Activity Reports (SARs) ,
Terrorist Financing Regulations ,
U.S. Treasury
On June 24, the Office of the Comptroller of the Currency (OCC) announced it is requesting comments on proposed amendments to its recovery planning guidelines. A recovery plan’s purpose is to provide a covered bank with a...more