Changes to Bank Merger Review Process Announced by Federal Agencies

On September 17, 2024, the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) separately finalized previously proposed policy statements on their review of bank mergers under the Bank Merger Act (BMA) and its implementing regulations. Noticeably missing in action was the Board of Governors of the Federal Reserve System, who has not issued any policy statement that would update or amend its review of bank mergers. Also on September 17, 2024, the Department of Justice (DOJ) formally withdrew from the 1995 joint Bank Merger Guidelines and issued commentary on its plans to transition to the 2023 Merger Guidelines for its review of bank mergers.

Read the full Alert on the Duane Morris LLP website.

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