The OCC is restoring its former practices and policies under the Bank Merger Act to reinstate expedited merger reviews and streamlined business combination applications.
By Arthur S. Long, Pia Naib, Connor Jobes, and Deric Behar
On May 8, 2025, the Office of the Comptroller of the Currency (OCC) issued an interim final rule (Interim Final Rule) to rescind a 2024 final rule (2024 Final Rule) that amended the OCC’s bank merger application review procedures. The OCC simultaneously
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.
By Arthur S. Long, Pia Naib, and Deric Behar
On March 21, 2024, the Board of Directors of the Federal Deposit Insurance Corporation (FDIC) approved Proposed Revisions to its Statement of Policy on Bank Merger Transactions (the Proposal). The Proposal adopts a principles-based approach and aims to update, strengthen, and clarify the FDIC’s