Read the RFI from the FDIC Here

  • Source: fdic.gov

Treliant Takeaway:

The financial system is changing with the introduction of FinTechs, increased reliance on internet banking and continued consolidations through mergers and acquisitions.  As a result, regulators continue to evolve and change expectations; banks must adapt and be prepared for the possibility of more complicated merger and acquisition applications and final decisions from regulators to take longer.

Highlights:

In response to the Biden administration’s executive order in July, 2021 directing federal regulators to strengthen oversight of bank mergers, the FDIC issued a request for information (RFI) on March 25,2022.  The RFI requests comments on the effectiveness of the existing framework in light of today’s ever-changing financial system landscape.

The FDIC is asking for input in many areas such as:

  • What additional requirements or criteria should be included to address financial stability risk factors of proposed acquisitions and mergers?
  • To what extent should capital levels, management quality and earnings be considered for approval?
  • Is reliance on the Community Reinvestment Act performances enough, or should additional considerations be made? Should the CFPB have input into the convenience and needs factor currently included in the evaluations?
  • Should there be different standard or criteria used for transactions between smaller institutions?

Author

Lorraine Faust

Lorraine Faust, a Senior Manager with Treliant, is a regulatory and compliance professional with over 25 years’ experience in the financial services industry. She has worked in small, mid-size, and large financial institutions in both internal audit and compliance. Knowledgeable in a wide range of consumer protection laws, Lorraine’s focus…