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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, 2025, the Office of the Comptroller of the Currency (OCC) announced its adoption of an interim final rule (IFR) that amends its 2024 final rule related to its regulations for business combinations involving national...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
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
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
On April 10, the OCC announced a notice published in the Federal Register extending the comment period for the OCC’s proposed rule on bank mergers. The NPRM titled, “Business Combinations under the Bank Merger Act,” was...more
The U.S. Office of the Comptroller of Currency (OCC) released a notice of proposed rulemaking (NPR) seeking to “increase the transparency of the standards that apply to the agency’s review of business combinations involving...more
On January 29, the OCC announced a proposed rule for bank merger approvals under the Bank Merger Act (BMA). The OCC proposed changes to 12 CFR 5.33 to reflect its view that a business combination is a significant corporate...more
OCC Requests Public Comments on Proposed Bank Merger Policy Statement and Rules The OCC has proposed a new policy to increase the transparency of the standards that the agency applies to review business combinations involving...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