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The Italian government has recently published its 2024 Annual Report on Foreign Direct Investment (the Report), providing an overview of the exercise of its special powers, commonly referred to as “Golden Power,” in sectors...more
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
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 March 17, the Office of the Comptroller of the Currency (OCC) announced that the agency granted conditional approval for a leading FinTech company to indirectly acquire a nationally chartered bank, enabling the FinTech...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
In 2024, the U.S. federal bank regulators were extremely active, with initiatives ranging from antitrust and capital to proposals regarding controlling shareholders and incentive-based compensation. Climate issues and...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
On September 17, the OCC approved a final rule amending its procedures for reviewing applications under the Bank Merger Act. The rule will aim to provide clearer guidelines for institutions regarding the OCC’s review process...more
The Office of the Comptroller of the Currency (OCC) released guidance regarding its planned changes to the Bank Merger Act (BMA). The New Rule: Explicitly adds financial stability as a key factor for assessing mergers,...more
When federal agencies review bank mergers, the competition issues typically relate to the number and location of physical branches and the extent of any overlap in the areas served. By contrast, the proposed $35 billion...more
On May 17, Fed Governor Michelle Bowman delivered a speech to the Pennsylvania Bankers Association focusing on bank regulatory reform, opportunities for engagement, bank mergers and acquisitions, third party risk management,...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
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 Federal Deposit Insurance Corporation (FDIC) is ready and eager to make some updates to the guidelines it applies when reviewing potential bank merger transactions. This comes nearly three years after President Biden...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 Office of the Comptroller of the Currency (“OCC”) recently sought comment on a proposed rule designed to increase the transparency of the standards applicable to the OCC’s review of business combinations (i.e., bank...more