Financial Stability Considerations For Bank Merger Analysis

By Greg Baer, Bill Nelson and Paige Pidano Paridon (May 16, 2022, 5:43 PM EDT) -- Financial stability concerns of bank mergers are a hot topic. Since enactment of the Dodd-Frank Act in 2010, the federal banking agencies have considered risks to financial stability when evaluating proposed bank mergers and acquisitions, and have found in each case that they did not argue against approval.

However, the Federal Deposit Insurance Corp. is currently seeking comment on a reconsideration of the framework for assessing the financial stability risks that could arise from a merger involving a large bank.[1] Its request for information bemoans increasing consolidation in the banking industry, consistent with a recent executive order directing federal agencies to...

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