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On July 15, the FDIC Board approved the publication of a request for information on how the FDIC should review filings submitted by industrial banks and industrial loan companies....more
On July 5, 2025, the FDIC finalized (and published in the Federal Register) its decision to rescind its 2024 Bank Merger Statement of Policy and reinstate its prior, long-standing version. We previously covered the proposed...more
Mergers and acquisitions continue to be a critical strategy for banks aiming to bolster their market presence and operational efficiency. The United States has 4,500+ banks, 4,000+ credit unions, and a large number of...more
On May 20, the FDIC announced its intent to rescind the 2024 Statement of Policy and reinstate its prior Bank Merger Statement of Policy. This decision reflected the FDIC’s assessment that the 2024 Statement of Policy added...more
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
April 18, 2025 - The Federal Reserve and the Office of the Comptroller of the Currency have conditionally approved the merger of Discover Bank, Greenwood, Delaware, into Capital One, National Association, McLean, Virginia....more
The Trump Administration has made clear that it intends to lessen the barriers to bank merger and acquisition activity. As we previously noted, the FDIC has moved to lower some of the impediments to mergers under its 2024...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
While the Trump Administration’s approach to bank regulation has been the subject of much speculation, specific proposals have yet to emerge, and the administration has yet to name key personnel in the regulatory agencies. ...more
On January 20, the FDIC appointed Travis Hill as Acting Chairman. In a prepared statement the next day, Hill outlined his agenda to address changes at the Corporation. Among other efforts, he announced a wholesale review of...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
Key Points - - New leadership at the financial regulatory agencies is likely to reverse some Biden-era rules and policy statements. - President-elect Trump’s picks are expected to make industry-friendly changes in a...more
Alex Barrage, a partner with Troutman Pepper Locke, was quoted in the January 7, 2025 CNBC article, “Wall Street Notches Another Win as Fed’s Barr Clears the Way for Gentler Banking Regulator.”...more
This regular publication from DLA Piper focuses on helping banking and financial services clients navigate the ever-changing regulatory landscape. In this edition: CFPB issues final rule on personal financial data rights...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
On September 17, the FDIC Board approved its Final Statement of Policy on Bank Merger Transactions (SOP), updating the guidelines for evaluating bank mergers. The OCC recently released its final rule on the BMA to provide...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
On Sept. 17, 2024, the Federal Deposit Insurance Corporation (FDIC) Board met to finalize an updated approach to increase scrutiny of bank mergers, particularly those that would result in a bank with over $100 billion in...more
On September 17, the DOJ announced its withdrawal from the 1995 Bank Merger Guidelines, stating the 2023 Merger Guidelines will be the only authoritative statement across all industries. This decision followed collaboration...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