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ARTICLE · 26 FEBRUARY 2024

OCC Proposes Changes To Merger Review Process

K&L Gates
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On 29 January 2024, the Office of the Comptroller of the Currency (OCC) issued a notice of proposed rulemaking (NPR) regarding its review of Bank Merger Act (BMA) applications.

United StatesCorporate/Commercial Law
Grant F. Butler
Grant F. Butler
Robert M. Tammero, Jr
Robert M. Tammero, Jr
Yuki Sako
Yuki Sako

INTRODUCTION

On 29 January 2024, the Office of the Comptroller of the Currency (OCC) issued a notice of proposed rulemaking (NPR) regarding its review of Bank Merger Act (BMA) applications. The NPR was released immediately following a speech by Acting Comptroller of the Currency Michael Hsu in which he commented on the US banking system, including actions the OCC is taking to improve transparency in the OCC's review and approval process for proposed bank mergers. The NPR consists of two proposals:

  • regulatory changes to the OCC's bank merger review procedures; and
  • a new policy statement (Proposed Policy Statement) that summarizes the principal factors that the OCC would consider in reviewing proposed mergers under the BMA.

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