State Regulators Support Modernizing Regulatory Framework for Bank Mergers
A modernized regulatory framework for bank merger transactions should reflect changes in financial services, the diversity of consumer and small business needs and the interests of community banks, CSBS said in a comment letter to the FDIC.
The FDIC has solicited comments as it undertakes a comprehensive review of all aspects of the existing regulatory framework applicable to bank merger transactions.
In a letter filed Tuesday, CSBS recommended that the FDIC:
- Reevaluate the Herfindahl-Hirschman Index calculation in light of technological innovations, market expansion and consumer preferences;
- Consider how banks reach customers through new technologies when accounting for market share and concentration;
- Create a de minimis exception for certain transactions to preserve the viability of community banks;
- Incorporate the role of states in the federal regulatory framework of bank merger transactions;
- Promote alignment and consistency across the federal banking agencies and the DOJ; and
- Provide greater clarity around the objective, scope, and criteria of modernizing the regulatory framework for the benefit of regulators, the banking industry and the public.
Subscribe to CSBS
Stay up to date with the CSBS newsletter