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Comparing the Agencies' Proposals to Change Bank Merger Reviews

Alert

The OCC and the FDIC have recently issued proposed policy statements that in many ways would change how they review bank merger applications.  At a high level, the proposals show that the current leadership of these banking agencies are, and have been, adopting a more skeptical view of bank mergers than in the past.  In this client alert, we compare the two proposals and highlight some key takeaways for banks considering M&A in the current and emerging environment.

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