On May 20, federal merger policy took a sharp turn as the FDIC voted to rescind its 2024 merger guidelines, and the U.S. House passed a Congressional Review Act (CRA) resolution to repeal the OCC’s 2024 merger rule....more
On May 8, the Office of the Comptroller of the Currency (“OCC”) issued an interim final rule rescinding the 2024 final rule to OCC merger procedures and an accompanying policy statement....more
The Federal Deposit Insurance Corporation (“FDIC”) is requesting public comment on its proposal to rescind its 2024 Statement of Policy on Bank Merger Transactions (“2024 Policy Statement”) and reinstate its prior Statement...more
Under its new acting chairman appointed by President Trump, the FDIC charges ahead with its new agenda by rolling back key Biden-era regulatory efforts. On March 3, 2025, the Federal Deposit Insurance Corporation (FDIC)...more
As the new administration settles in, it has begun to catalyze significant changes in the bank supervisory and regulatory environment. The FDIC is the first mover in this effort. Longtime director and sometime Chairman Martin...more
Federal banking agencies under a second Trump Administration are expected to be more receptive to industry proposals for bank mergers, acquisitions, and related transactions. We've previously explored national trust banks and...more
Regulators seek to provide clarity and transparency on the bank merger review process, but changes may increase application complexity and unpredictability. Consistent with ongoing initiatives to strengthen US antitrust...more
The FDIC, OCC, and U.S. Department of Justice (DOJ) have coordinated the release of new policies that will govern each agency’s consideration of bank merger transactions. The FDIC and OCC each published final statements of...more
Last week, each of the Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency (OCC), and the Department of Justice Antitrust Division (DOJ) revised how they will review bank mergers. Our...more
The FDIC proposed revisions last month to its existing policy on how it evaluates merger transactions that require the FDIC's approval under the Bank Merger Act (BMA). ...more
The Federal Deposit Insurance Corp. and the Office of the Comptroller of the Currency recently announced proposals to update their approaches to evaluating bank mergers and other business combinations under the Bank Merger...more
Editor's Note - The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency,...more
On March 21, the Federal Deposit Insurance Corporation (FDIC) published for comment a proposal (Proposal) to revise its Statement of Policy on Bank Merger Transactions (SOP). If adopted as proposed, the Proposal would modify...more
The Proposal clarifies the FDIC’s bank merger approval process but may prove challenging for new large bank consolidations with the FDIC as the primary regulator. On March 21, 2024, the Board of Directors of the Federal...more
On March 21, 2024, the FDIC unveiled proposed revisions to its Statement of Policy (SOP) on Bank Merger Transactions, which was last amended in 2008. The revisions would increase scrutiny of bank mergers, particularly mergers...more
On March 21, the FDIC issued a request for comment on its proposed Statement of Policy (SOP) on bank merger transactions, which will aim to update, strengthen, and clarify the FDIC’s approach to bank merger evaluation. The...more
In This Issue. The U.S. Securities and Exchange Commission (SEC) proposed rules to include certain significant market participants as “dealers” or “government securities dealers” to essentially eliminate the trader exclusion...more
On February 7, Acting Chairman Martin J. Gruenberg announced the Federal Deposit Insurance Corporation's (FDIC) priorities for 2022, including undertaking a comprehensive review of the process of considering and evaluating...more