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
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
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
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
The Proposal clarifies the FDIC’s bank merger approval process but may prove challenging for new large bank consolidations with the FDIC as the primary regulator. On March 21, 2024, the Board of Directors of the Federal...more
On March 21, 2024, the FDIC unveiled proposed revisions to its Statement of Policy (SOP) on Bank Merger Transactions, which was last amended in 2008. The revisions would increase scrutiny of bank mergers, particularly mergers...more
On March 21, the FDIC issued a request for comment on its proposed Statement of Policy (SOP) on bank merger transactions, which will aim to update, strengthen, and clarify the FDIC’s approach to bank merger evaluation. The...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
On January 29, 2024, the Office of the Comptroller of the Currency (the “OCC”) proposed guidance in the form of a policy statement to provide greater transparency around the factors considered by the agency when approving...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
On February 7, Acting Chairman Martin J. Gruenberg announced the Federal Deposit Insurance Corporation's (FDIC) priorities for 2022, including undertaking a comprehensive review of the process of considering and evaluating...more
On July 9, 2021, President Joseph R. Biden, Jr. signed an executive order "on promoting competition in the American economy" (the "Order"). The White House characterized the Order as an effort to reduce the trend of...more
Against a global backdrop that saw M&A slip 9% by both value and volume year on year, the financial services sector was one of a few outliers. M&A value in the industry climbed 14% in 2019, to a total of US$343.3 billion...more
Election Day brought an end to a long period of uncertainty that caused market fluctuations and delayed business planning decisions. As we navigate the post-election landscape, many questions remain regarding the potential...more