News & Analysis as of

Office of the Comptroller of the Currency Mergers Regulatory Reform

Sheppard Mullin Richter & Hampton LLP

FDIC Rescinds 2024 Merger Guidelines; House Votes to Repeal OCC Rule Under CRA

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

Orrick, Herrington & Sutcliffe LLP

OCC to restore its streamlined Bank Merger Act regulations

On May 8, the OCC adopted an interim final rule to restore streamlined application and review procedures under the Bank Merger Act. The rule aims to provide clearer guidelines for institutions regarding the OCC’s review...more

Cadwalader, Wickersham & Taft LLP

Certainty and Uncertainty, May 2025 - OCC Issues Interim Final Rule Undoing 2024 Merger Rule and Guidance

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

Davis Wright Tremaine LLP

OCC Reverts to Prior Merger Rules

The Office of the Comptroller of the Currency (OCC) has issued an interim final rule that restores streamlined and expedited regulatory procedures to review applications under the Bank Merger Act for business combinations...more

Husch Blackwell LLP

OCC Aims to Streamline Bank Merger Reviews

Husch Blackwell LLP on

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

Nutter McClennen & Fish LLP

Nutter Bank Report: March 2025

The federal banking agencies have announced their intent to issue a proposal to rescind the Community Reinvestment Act (CRA) final rule originally issued in October 2023. In their announcement on March 28, the agencies also...more

Cadwalader, Wickersham & Taft LLP

Regulation in Flux, March 2025 - OCC Gives Green Light to National Bank Fintech Business Model

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

Davis Wright Tremaine LLP

New Administration Outlook: FDIC Moves To Rescind Key, Controversial Proposals

The FDIC has signaled the reversal of key, controversial proposals from 2024. In doing so, it has provided welcome clarity on important areas that implicate banks of various sizes and charter types, allowing banks to focus on...more

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