Read the RFI from the FDIC Here

  • Source:

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.


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?


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…