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?