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Agencies Finalize Changes to Bank Merger Review Policies

Alert September 2024

Agencies Finalize Changes to Bank Merger Review Policies

September 2024, Covington Alert

On September 17, 2024 the OCC and the FDIC finalized policy statements that change how these agencies review bank merger proposals. That same day, the U.S. Department of Justice withdrew from the 1995 Bank Merger Guidelines and announced that it will instead evaluate the competitive impact of bank mergers using its 2023 Merger Guidelines that apply across all industries. At a high level, the final OCC and FDIC statements of policy and the DOJ’s withdrawal from the 1995 Bank Merger Guidelines demonstrate that the current leadership of these agencies is adopting a more skeptical view of bank mergers than in the past.

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