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On July 15, 2025, the Federal Reserve Board released a proposed rule to revise the Large Financial Institution rating system or "LFI Framework." The proposal would change how the Fed evaluates the financial and managerial...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
On March 17, the OCC announced it had conditionally approved an application of a fintech to change the business model of a nationally chartered bank upon acquisition of the bank by the fintech, specifically allowing the...more
On March 17th, the Office of the Comptroller of the Currency (“OCC”) conditionally approved the application for the newly renamed SmartBiz Bank N.A. (“SmartBiz Bank”) to change its business model in support of its fintech...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
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
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
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
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
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
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
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
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, specifically...more
On September 7, 2022, newly-appointed Vice Chair for Supervision at the Federal Reserve (the “Fed”), Michael S. Barr, gave a speech outlining his near-term goals and the “holistic approach” he intends to take to achieve them....more
In this Issue. The Office of the Comptroller of the Currency (OCC) is seeking feedback on principles for climate-related financial risk management for large banks; the Department of Justice’s Antitrust Division is seeking...more
In This Issue. The Board of Governors of the Federal Reserve System (Federal Reserve), in response to an increased number of inquiries and access requests from companies with fintech and other narrow purpose charters, invited...more
SEC Charges Trust Company with Operating Unregistered Investment Companies and Failing to Register Securities Offerings. On September 30, the Securities and Exchange Commission (SEC) announced it had settled charges with...more
The Trump administration has provided few specifics regarding its plans for financial regulatory reform. But Republican control of the executive and legislative branches of the federal government should create a favorable...more