OCC Announces New Bank Merger Policies
By: Grant F. Butler, Robert M. Tammero, Jr, Yuki Sako, and Aiden D. O’Leary
On 29 January 2024, Acting Comptroller Hsu gave a speech articulating his vision that the US banking system should support the diversity, dynamism and the size of the US economy, and unveiling proposed updates to the OCC merger application review processes. Shortly thereafter, the OCC issued a notice of proposed rulemaking (NPR) proposing to (i) eliminate automatic expedited approval based on passage of time and inaction by the OCC, which would result in every bank merger or consolidation application requiring a deliberate approval by the agency; and (ii) adopt a policy statement containing factors and indicators considered by the agency in reviewing such applications, and principles that will guide the OCC decision making process, including factors such as financial stability, financial and managerial resources and future prospects, and convenience and needs. OCC is accepting comments on the NPR which are due 60 days after publication in the federal register.
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